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Full text of "Evidence Against Dr. Colin A. Ross, vol. 1"

INTRODUCTION 

It was in 1985 that a Winnipeg psychiatrist Dr. Colin A. Ross first introduced a radical 
form of pop psychiatry into Manitoba health care. From 1985 to 1991 Ross divided his 
time between the St. Boniface General Hospital, the University of Manitoba and 
preaching his new found mental health ideas at seminars. Ross has been described as a 
young, charismatic and dynamic speaker. 

Although Dr. Ross did not have the medical, scientific or police evidence to back up his 
ideas, he nevertheless maintained that almost all emotional disorders (anxiety, 
depression, dysfunctional relationships etc.) and many mental illnesses were caused by 
childhood incest or childhood assaults by Satanic cults. And if Ross's patients could not 
recollect memories of the sexual assaults, Ross would tell them that they (the patients) 
had involuntarily blocked out or repressed the abuse memories and that the repressed 
memories resided in the patient 'alters' which were not accessible to the conscious 
memory (or host alter). By the use of brainwashing techniques (suggestive questioning, 
drug therapy, hypnosis, calling out alters, age regression, group validation etc.) Ross had 
no difficulty convincing his patients that their disorder was the result of childhood incest 
and/or Satanic cult abuse. Two of Dr. Ross's favorite psychiatric medications were 
prescribing overdoses of Halcion (triazolam) and giving sodium amytal injections. Ross 
also performed experimental new drug testing for large Drug Corporations. 

Patients would readily produce horrendous false memories of incest and/or having been 
abused by Satanic cults to account for their illness. Ross would diagnose these patients as 
having Multiple Personality Disorder (MPD) and his treatment plan was to uncover the 
memories and integrate the alter personalities into one. There was no scientific or medical 
basis for this diagnoses and plan of treatment. 

According to Roma Hart (Ross's patient from 1986 to 1991) all of Ross's MPD patients 
became suicidal. Hart says Ross would encourage his drug induced patients to commit 
suicide. By way of sworn statements, and other evidence, this Dossier alleges that Ross 
was dismissed from his position at the St. Boniface General Hospital in 1991 for causing 
the wrongful deaths of five patients. Ross's dismissal was concealed and covered up, 
allowing him to become certified by the Texas State Board of Medical examiners. After 
assessing the drug prescription resume of Roma Hart as a patient of Dr. Ross, it is the 
writer's view that Ross attempted to cause Hart's death by way prescribing massive 
overdoses of drugs and suggesting to her that she commit suicide. 

In July 1998 Dr. Colin A. Ross was charged with fraud, gross negligence, fraudulent 
concealment, and conspiracy to commit fraud in the State of Texas. He was charged in 
Texas for practicing the same fraudulent medicine that he practiced at the St. Boniface 
General Hospital from 1985 to 1991. Charges were also filed against Ross in the 
Manitoba Court of Queen's Bench inl994 and 1997. To date no one has been successful 
in getting Ross into Court. Numerous unsuccessful complaints have been launched 



continued 



against Ross to The College of Physicians and Surgeons of Manitoba, The Texas State 
Board of Medical Examiners and The Royal College of Physicians of Canada. The 
Canadian Psychiatric Association has also been made aware of at least some of these 
complaints against Ross. 

The following doctors are experts and familiar with Dr. Ross' s medical practices, and the 
writer encourages readers to consult with them as professionals in the health care field: 

1 . Dr. Richard Ofshe, Professor at Berkley and a Pulitzer prize winner; 7112 Marlboro 
Terrace, CA. 94705, Tel: 510-845-491 1. 

2. Dr. Harold Merskey, London Psychiatric Hospital, 850 Highbury Avenue, P.O. Box 
2531, London, ON. N6A4H1, Tel: 519-672-2298. 

3. Dr. August Piper, 901 Boren #701 Seattle WA. 98104, Tel: 206-623-5757. 

4. Dr. Christopher Barden (Phd. in Psychology & Attorney at Law) Salt Lake City, 
Utah, Tel: 801-294-0600. 

5. Dr. Jonathan Werier, 205-2265 Pembina Highway, Winnipeg, MB. R3T 2H2, 
Tel: 204-26 1-9761. (Dr. Werier is George Bergen's family physician) 

For further insight into Dr. Colin Ross's unscientific ideas please refer to the quotations 
under TAB A, Volume I, taken from two of his books written in 1989 and 1994. 

In 1990 the Minister of Health for the Province of Manitoba, Donald Orchard, bought 
into Ross's unscientific mental health ideas with devastating consequences to many 
Manitoba families. 



George Bergen, B.Sc. 
October 28, 1998 



1998 EVIDENCE 

[VOLUME I] 



INDEX - SUMMMARIES 



TAB A. A 1998 Affidavit of Roma Elizabeth Hart: 

A former patient of Dr. Colin A. Ross from 1986 to 1991 states that she was 
wrongfully diagnosed by Ross who used brainwashing techniques to implant false 
childhood memories. Hart states that she witnessed the wrongful deaths of Ross's 
patients, and that Ross prescribed massive, noxious doses of psychiatric drugs to her 
(Hart) at the St. Boniface General Hospital in Winnipeg for five years. 
Documentaton: 

- Quotations taken from Dr. Colin Ross's 1998 and 1994 books that forms 
the basis of Ross's unscientific and dangerous pop psychiatry. 

- Refer also to TAB N, VOLUME I. 



TAB B. A 1998 Affidavit of George Bergen: 

In a private investigation, George Bergen discovers that Dr. Colin Ross, 

(a) did not leave his position at the St. Boniface General Hospital in 1991 on a 

voluntary basis (see TABs C & D) as reported and, (b) Bergen states that Dr. Ross is 

responsible for four wrongful deaths at the St. Boniface General Hospital and one 

wrongful death at the University of Manitoba. 

Documentation: 

- The 1 986 death certificate of Phyllis Peters dated July 20, 1986. 

- A 1 996 Affidavit of George Bergen. 

- Excerpts from sworn statements by Dr. Colin Ross on July 24, 1 995, in a 
Minnesota Court wherein Ross describes his work at the University of 
Manitoba. Phyllis Peters was an outpatient at Ross's Clinic at the University 
of Manitoba at the time of her death on July 20, 1986 



TAB C. A 1998 Affidavit of Robert Alexander Cowan: 

As a former Director of Mental Health for the Province of Manitoba, 

Robert Alexander Cowan states that it was his understanding in 1991, 

that Dr. Colin A. Ross did not leave his position at the St. Boniface General Hospital in 

1991 on a voluntary basis and that the reason for Dr. Ross's leaving were covered-up 

and concealed from the public. 



TAB D. Correspondence addressed to The Sisters of Charity (The Grey Nuns), 

Proprietors of the St. Boniface General Hospital who served on the Hospital's 

Board of Directors between 1985 and 1991 when Dr. Colin Ross was employed at 

the said Hospital. A reply is received from the President of the St. Boniface 

General Hospital that indicates the possibility of legal action. 

Less then two weeks after writing the threatening letter, the President terminates 

his employment at the St. Boniface General Hospital. Bergen believes that the 

President may have been dismissed from his position at the St. Boniface General 

Hospital. 

Documentation: 

- A letter written by George Bergen to Sister Jacqueline St. Yves. 

- A letter written by Ken Tremblay, to George Bergen. 

- A Winnipeg Free Press report on Ken Tremblay President of the St. Boniface 
General Hospital regarding Mr. Tremblay' s termination. 

- A letter written by George Bergen to the Sisters of Charity. 

- A list of book titles and a listing of Psychiatrists. 

- A letter written by George Bergen to the Sisters of Charity. 

- Excerpts from the book Multiple Personality Disorder; by Colin A. Ross on 
his (Ross's) use of Sodium Amytal injections on MPD patients at the St. 
Boniface General Hospital 

- Excerpts from sworn testimony by Colin A. Ross on his use of Sodium 
Amytal injections of patients at the St. Boniface General Hospital. 



TAB E. Petitions by citizens from across Canada, the United States and Great 

Britain demanding that Dr. Colin Ross be brought to justice for crimes against 
humanity affecting the most vulnerable members in society. These petitions 
represents over 1000 signatories. 

Documentation: 

- Excerpts from sworn testimony by Colin Ross in a Minnesota Court on June 
30,1995 concerning his (Ross's) seminars. 



TAB F. In 1998, MarthaAnn Tyo from Dallas, Texas brought charges against Dr. Colin 
Ross for fraud, negligence, fraudulent concealment, and conspiracy to commit 
fraud. Dr. Ross also faces charges under the Deceptive Practices Consumer 
Protection Act in the State of Texas. The charges in Dallas are for the same 
medical fraud that Ross was practicing at the St. Boniface General 
Hospital from 1985 to 1991. Similar actions were launched against 
Ross in Winnipeg in 1994 and 1997. 
Documentation: 

- A Press Release, dated July 30, 1998. 

- A Winnipeg Free Press report dated August 24, 1998 

- Refer also to TABs A, G, H and N, VOLUME I. 



TAB G. A Testimony of Thomas Brown: 

- Thomas Brown's wife was a patient of Dr. Colin A. Ross in Dallas, Texas. 



TAB H. In 1990, Dr. Colin Ross arranged for a City of Winnipeg Police Detective 
Russ Heslop to interview his (Ross's) Multiple Personality Disorder (MPD) 
patients at the St. Boniface General Hospital. Ross's patients disclosed 
horrendous false stories of childhood sexual assaults by family members who were 
allegedly involved in Satanic Cults. Detective Heslop produced a 29 page Police 
Report in which he (Heslop) alleged Satanic Cult activities at various locations in 
Manitoba. Roma Elizabeth Hart was one of Ross's MPD patients interviewed by 
Detective Heslop. Ross then used the Heslop Report to create a wave of Satanic 
Cult public hysteria in Manitoba. The Minister of Health Don Orchard bought 
into Ross's fraudulent medical practices with devastating consequences for 
hundreds of families in Manitoba, (documented evidence implicating the Manitoba 
Government in this fraud is analyzed in VOLUME II) 
Documentation: 

1 8 newspaper reports pertaining to false and/or implanted abuse memories. 
- Excerpts of Colin Ross's July 25, 1995 sworn statement in a Minnesota 

Court on his (Ross's) reasons for leaving Manitoba in 1991. 



TAB I. A sworn statement by Karen and John Perchotte with a reference to Dr. Colin 
Ross. 

Documentation: 

- The results of a Polygraph test clears Mr. Perchotte of sexually assaulting his 
daughter. This is one more case of a therapist implanting false memories to 
fraudulently account for the emotional problems of a vulnerable client. 

- The Curriculum Vitae of Lome Huff, test administrator. 



TAB J. A sworn statement by Julia and Edward Balik with a reference to Dr.Colin Ross. 



TAB K. A sworn statement by Lawrence Kyle with reference to Dr. Colin Ross. 



TAB L. A sworn statement by Niall Rennie with a reference to Dr. Colin Ross. 



TAB M. A sworn statement by Gail and Wilhelm Dueck with a reference to Dr. Colin 
Ross. 



TAB N. A sworn statement by Roma Elizabeth Hart, a patient of Dr. Colin Ross with 
references to Ross's criminal conduct at the St. Boniface General Hospital. 
Ross carries out many experimental drug testing contracts on his patients at the 
St. Boniface General Hospital. 

Documentation: 

- A medical statement by Dr. Ross wherein he admits 

to prescribing 100 times the manufacturer's recommended dosage of the 
psychiatric drug Halcion (Triazolam) to his patient Roma Elizabeth Hart. 

- Examples of Ross's medical prescriptions of Halcion (Triazolam) as 
recorded by the pharmacy at 5-938 Carrigan Place in Winnipeg on June 1 1, 
1990 and June 28, 1990 respectively. 

From the Compendium of Pharmaceuticals; Thirty first edition, 1 996. 
[see page 596: it states that the maximum dosage of Halcion (Triazalom) must 
not exceed 0.5 mg. per day, yet Dr. Ross prescribed that Roma take 51 mg per 
day as per his medical report. The Compendium also states that death can 
result from overdoses of Halcion] 

- Excerpts from Ross's 1995 sworn testimony on experimental drug testing. 



TAB O. A sworn statement by Anne and William Lambert with a reference to Dr. Colin 
Ross. 



TAB P. A sworn statement by Margaret and Michael Juce with a reference to Dr. Colin 
Ross. 



TAB Q. A sworn statement by Use Babletek with a reference to Dr. Colin Ross. 
TAB R. 1996 sworn statements by George Bergen with references to Dr. Colin Ross. 



TAB S. Newspaper reports attesting further to the damages caused to families by the 
fraudulent therapy first introduced into Manitoba by Dr. Ross in 1985. 



AFFIDAVIT 
Re: Dr. Colin A. Ross 

Affidavit of Roma Elizabeth Hart 

I, ROMA ELIZABETH HART, of the City of Winnipeg in the Province of MANITOBA, 
CANADA, MAKE OATH AND SAY: 

1 That in 1986, 1, Roma Elizabeth Hart was enrolled as a student in the Faculty of 
Education at the University of Manitoba. 

2 That in October 1 986, 1, Roma Elizabeth Hart, due to personal stress, was referred 
Dr. Colin A. Ross at the St. Boniface General Hospital in the City of Winnipeg. 

3 That in October of 1 986, 1, Roma Elizabeth Hart was wrongfully diagnosed by Dr. 
Colin A. Ross as having Multiple Personality Disorder (MPD) caused by alleged 
repressed memories of childhood sexual assaults by my family members and Satanic 
cults. I, Roma Elizabeth Hart had no memories of the alleged assaults. 

4 That as a patient of Dr. Ross from October 1 986 to November 1991 , 1, Roma Elizabeth 
Hart was subjected to brainwashing memory recovery techniques that included hypnosis, 
age regression, dream imaging, leading and suggestive questioning, MPD group 
validation therapy, body memories, and massive toxic levels of psychiatric drugs. 

5 That in the MPD group validation therapy sessions under Ross' s care and direction at the 
St Boniface General Hospital, I, Roma Elizabeth Hart, witnessed and became aware that 
there were other patients (under Ross's care) who were being brainwashed into falsely 
believing that they (Ross's patients) too had been sexually assaulted in their childhood 
by members of their own family and/or by Satanic cults. 

6 That from October 1 986 to November 1 99 1 , as a patient of Dr. Ross at the St. Boniface 
General Hospital, I, Roma Elizabeth Hart witnessed and/or became aware of five 
wrongful deaths as the result of unscientific and fraudulent therapeutic medical practises 
administered to patients under the care of Dr. Colin A. Ross at the St. Boniface General 
Hospital, in the City of Winnipeg. 

- — continued - — 



7. That during the period that I, Roma Elizabeth Hart was a patient of Dr. Ross at the St. 
Boniface General Hospital from October 1986 to November 1991 , 1, Roma Elizabeth 
Hart became aware that all of Dr. Colin Ross's MPD patients were suicidal or became 
suicidal, and that there where many suicide attempts by Ross's patients. 

8. That during the period from October 1 986 to November 1 99 1 , 1, Roma Elizabeth Hart 
became aware that following a suicide attempt by his (Ross's) patients, Dr. Colin 
Ross would question them about their near death experiences. 

9. That between 1 986 and 1 99 1 Dr. Colin A. Ross encouraged me, Roma Elizabeth Hart 
and another patient of his, Wanda Davenport, a close friend of mine, to commit suicide 
on more than one occasion. I, Roma Elizabeth Hart hereby submit that Wanda 
Davenport's death in 1991 was one of the five wrongful deaths that I became aware of as 
the result of Dr. Colin A. Ross's medical practices at the St. Boniface General Hospital 
from 1986 to 1991. 



I, ROMA ELIZABETH HART, do solemnly swear that the contents of this AFFIDAVIT to be 
true. 



SWORN before me 
In the City of Winnipeg 
In the Province of 



initoba, CAIN ADA n V a - , > I . / 4- 

/<to5£o3 . 1998 ad. ) hcrwdf ^Jctykth; H^T 

,? ) Roma Elizabetrffiart (deponent) 

) 




Commission^ 

My Commission expires 

on- 7?£r»wU- } b , 2000 AD. 



COLIN ROSS M.D. ON CHILD ABUSE, REPRESSED MEMORIES 
mSSOCIATION AND MULTIPLE PERSONALITY DISORDER(M.P.D.) 



Here are excerpts from Dr. Colin Ross's 1989, Multiple Personality Disorder, textbook 
and his The Osiris Complex(\994) that has made Manitoba into the iatrogenic (therapy 
induced symptoms or illness) capital of North America. 

" In my view , splitting and dissociation are synonyms. I believe that repression is a form 
of dissociation(Jorn, 1982), dissociation being a general term, Which terms are used in 
which way is not essential, but it is necessary to arrive at consistent use of terms in the 

field." 

C.Ross, M.D. P. 69 

Multiple Personality Disorder, 1989: 



« it is necessary to ask in detail about child abuse in every assessment and try to 

understand whether the person's symptoms and problems are related to childhood 

trauma." 

C. Ross, M.D. 

The Osiris Complex: 1994 

P. 47 

" When I am assessing a patient with the features of chronic trauma disorder and can 
contact pre-existing alter personalities, I feel good because I know what to do and have an 
effective treatment to offer. When there are no alters, I feel much less happy." 

Colin Ross, M.D. 1989 
Multiple Personality Disorder, P. 203 

" MPD patients have taught me that virtually all symptoms in psychiatry are potentially 
trauma-driven and dissociative in nature." 

C. Ross, M.D. 

The Osiris Complex; 1994 

P. xiii 

" The blank spells result from the amnesia barriers between the different personality 
states When one personality has control of the body, another may not remember." 

C. Ross, M.D. 

The Osiris Complex; 1994, P. 49 



" Memories may initially come back as flashbacks, dreams, hallucinations, vague 
premonitions of upcoming flashbacks, inner reveries, overheard conversations between 

alters, diary entrees or physical symptoms." 

C. Ross, M.D. 

Multiple Personality Disorder; 1989 

P. 250 

" The intact family, for many North American children, has been a war zone of physical 

and sexual abuse, a private Vietnam." 

C. Ross, M.D. 

Multiple Personality Disorder; 1989 

P. 61 



" What better way to survive incestuous abuse than to imagine that it is happening to 

someone else?" 

C. Ross, M.D. 

Multiple Personality Disorder; 1989 
P. 61 



" Somatic memories and behavioral enactment's of specific abuse incidents can underlay 
bingeing, vomiting, purging, and other behaviors." 

(note: 'somatic' refers to body memories) 
" Freud did to the unconscious mind, with his theories, what New York City does to the 
ocean with its garbage. Instead of listening to the tales his patients were telling him about 
childhood trauma, Freud projected his theories onto them 'to explain' their symptoms." 

C. Ross, M.D., 1989 
Multiple Personality Disorder, P. 181 

" The patriarchal role for women , at least in our society, is a combination of sex object, 
doormat, and punching bag, MPD, then, is caused primarily by a sick social structure." 

C. Ross, M.D. 

Multiple Personality Disorder 

P. 69 

" The sexually abusive father is an embodiment of patriarchal corruption. Although 
officially abhorred, his behavior is consistent with societal norms. That is why incest and 
child pornography is so widespread: They are inevitable consequences of the power 
structure(here Ross reviews the feminist analysis; then goes on to say): 

There is a lot of truth in this analysis." 

C. Ross, M.D. 

Multiple Personality Disorder; 1989 



" la treatment, as the patient is exposed to her traumatic memories, which had been 
hidden behind amnesia barriers, dissociative symptoms transiently increase" 

C. Ross, M.D. 

Multiple Personality Disorder; 1989 

P. 59 



« one of her alters had a clear memory of aliens coming into her apartment, 

impregnating her, coming back later to remove the fetus, than returning years later to 
show her the half-human, half-alien child they were raising among the stars. This alter 
was mortified when I raised the possibility that the aliens were possibly not literally real:- 



Margaret made this claim before I had heard about the current epidemic of UFO 
abductions. I did not realize, when I heard Margaret's story, that thousands of people in 
North America have similar memories. 

If the abductions are real, it would appear that the human race is being used as breeders, 
with amnesia for the human participation implanted hypnotically by the aliens. 
Margaret taught me that there is a connection of some kind between UFO abductions and 
the use of women as breeders for Satanic cults." 

Colin Ross, M.D. 1989 
The Osiris Complex, P. 149 



" MPD is based not on defect but on talent and ability to dissociate to cope with 
overwhelming childhood trauma, which usually involved both physical and sexual abuse. 
MPD is a creative and highly effective strategy for preserving the integrity of the 

organism " 

C. Ross, M.D. 

Multiple Personality Disorder; 1989 

P. 2 



" Many professionals, however believe that MPD is an iatrogenic artifact." 

( iatrogenic means induced by the therapist, social worker or doctor) 

C. Ross, M.D. 
Multiple Personality Disorder; 1989 



P. 57 



" The voices in MPD occur when the different personalities talk to each other or to the 
part of the person who is in control most of the time." 

C. Ross, M.D. 
The Orisis Complex; 1994 
P. 49 
" My estimate is that MPD has a point prevalence of between 1 in 50 and 1 in 10,000 

persons in North America." 

C. Ross, M.D. 

Multiple Personality disorder; 1989 

P. 90 



" Over the next 10 years we may gain insight into an extremely intricate 
multigenerational transmission of incest involving amnesia, abusive paternal alters 
having intercourse with alters of their children and MPD mothers amnesiac for their own 
direct contribution to the cycle. Once the linear flaws are corrected in the feminist 
analysis, it provides an essential component of the full understanding of MPD." 

C. Ross, M.D. 

Multiple Personality Disorder; 1989 



" I have met many demons, devils, evil characters, representatives of Satan, and Satan 

himself in my MPD work." 

C. Ross, M.D. 

The Osiris Complex; 1994 

P. 124 

" Why is it scientifically impossible for demons to exist, in a universe characterized by 
black holes, neutrinos, nuclear fission and the Lorentz contraction?" 

C. Ross, M.D. 

The Osiris Complex; 1994 

P. 125 



" I see no reason at all why discarnate spirits should not actually exist, other than the 
reductionist insistence that all mind must be an epiphenomenon of brain." 
(note: the word discarnate does not appear in Webster) 

C. Ross, M.D. 

The Osiris Complex; 1994 

P. 125 



" It is not possible to understand the nature of the human mind without thinking carefully 

about demon possession." 

C. Ross, M.D. 

The Osiris Complex; 1994 

P. 124 



" How can one determine if an entity is an alter or a demon? This question would be 
dismissed as irrelevant by the vast majority of psychiatrists and psychologists, and 
regarded as unscientific. The Evil One taught me otherwise." 

C. Ross, M.D. 

The Osiris Complex; 1994 

P. 125 

" ESP was rejected because of scientific conservatism in the same way that the 
stethoscope , smallpox vaccinations, and the circulation of blood were initially rejected 

by the medical establishment." 

C. Ross, M.D. 

Multiple Personality Disorder; 1989 

P. 183 



" In my experience, complex MPD with over 15 alter personalities and complicated 
amnesia barriers is associated with a 100 percent frequency of childhood physical, sexual 

and emotional abuse." 

Colin Ross, M.D. 1989 

Multiple Personality Disorder 

P. 101 

" Serious inquiry as to whether one is in the presence of a demon is considered by 
mainstream psychiatry as unscientific on the basis of ideological prejudice, not science. 
The reductionist, atheistic bias of modern psychiatry which dismisses the reality of 

demons is just that, reductionism." 

Colin Ross, M.D. 1994 

The Osiris Complex 

P. 125 

" In fact, the question of the reality of demons has been disregarded by mainstream 

psychiatry on the same basis as childhood trauma, dissociation, hypnosis, and the 

paranormal were dismissed in the late nineteenth century." 

Colin Ross, M.D. 1994 

The Osiris Complex, P. 125 



AFFIDAVIT 
Re: Dr. Colin A. Ross 

Affidavit of George Bergen 

I, GEORGE BERGEN, of the City of Winnipeg in the Province of MANITOBA, CANADA, 
currently employed by the Manitoba Government Employees' Union as a Senior Research 
Officer, MAKE OATH AND SAY: 

1 . That on March 1 7, 1 998, 1 George Bergen, met with Sister Jean Ell, a member of the 
Catholic Church Grey Nuns, in the City of Winnipeg for the express purpose of 
discussing Dr. Colin A. Ross's medical practice at the St. Boniface General Hospital in 
Winnipeg from 1985 to 1991. 

2. That on March 17, 1998, Sister Jean EU, a member of the Sisters of Charity (Grey Nuns) 
who had served on the St. Boniface General Hospital Board of Directors, informed me, 
George Bergen, that Dr. Colin A. Ross did not terminate his employment 
relationship in 1991 with the St. Boniface General Hospital on a voluntary basis. 

The Grey Nuns are the proprietors of the St. Boniface General Hospital and have 
membership on the St. Boniface General Hospital Board of Directors. 

3 . That on March 1 7, 1 998, 1, George Bergen was informed by Sister Jean Ell that between 
1985 and 1991 there were three (3) suicide deaths at the St. Boniface General Hospital 
linked to Dr. Colin A. Ross's medical practices at the Hospital. 

— continued on next page- 



4. That I, George Bergen have evidence and have reason to believe that there were at 
least four (4) suicide deaths at the St. Boniface General Hospital and 

one (1) suicide death at the University of Manitoba as a consequence of Dr. Colin 
A. Ross's conduct and medical practices between 1985 and 1991. 

5. That I, George Bergen, have evidence that Dr. Colin A. Ross is responsible for and 
caused the death of Phyllis Edna Peters, age 39 on July 20, 1986 when she (Phyllis 
Peters) attended Dr. Colin A. Ross's therapy clinic at the University of Manitoba. 

I, GEORGE BERGEN, do solemnly affirm that the contents of this AFFIDAVIT to be true. 



SWORN before me 
in the Province of 
MANITOBA, CANADA 
on rfuaiu/jt , 1998, AD. 



<jt- </r\ , 



7r&& 



v dZ^7C &0<J> 



,cA. 



Commissioner of OATHS. 
My Commission expires 
on /lePi ,-20QQ?A.D. 




port of Medical Examine, 

■m 1 



MamToEa 

Attorney Genera! 

Office of the 

Chief Medical Examiner 



«* 



CaseNo,_ 



frztkc 



ne ol Deceases 



ISex 



Date ol Death 



Miss Pbvllis Edna PETERS 



F 21/7/36 



? 06- "^030 Pembina Highway. Winnipeg 



Date ol Sifih 

ll/?/l9k7 



Age j Marital Status 

39 D 



Race 

Wh 



Place ol Death (II Hospital or Institution Give Name) 



Victoria General Hospital 



Occupation 



MEDICAL CAUSE OF DEATH 

Parti 
Immediate Cause of Death 

Antecedent Causes. II Arty, 
Giving Rise to me immediate 
Cause la) Above. Slating Ihe 
Underlying Cause Last. 



AporoK. Interval Between 
Onset and Death 



<a| 



(°> 



AmitriTvr.vlene p oisoning. 

DUE TO Of as a consequence of 



DUE TO or as a consequence ol 



(c) 



Pan II 

Other Significant Conditions 
ContriDuting to tne Deam But 
Not Casually Related to me 
immediate Cause tat Above 



Depression. 



Autoosy \St No I Name ol Pathologist 

Heic 2L> i — I 



Dr. S. W. Chang 



TERNAL 
.AMINATION 



YES I Place Performed 
7: NO I 



Manne* ol Deam 
Natural 



Accidental i — i 



Homicide 



Undetermined 



D 
D 



Alcohol-Drug Related 1 



A! Worn 

At Home 

In a Public Place 

Otner 



Circumstances (Descnoe Briefly) 



Date Interim Death Cenilicate Issued 



Date Final Death Cenilicate Issued 

*ftx 9/1/87 



D 
E 

D 



Toxicology Specimen Forwarded To 



M.V.A. 
Dnver 
Passenger 
Pedestrian 



■ — ■ ! n Death Due to Trauma Dale Occurred 

I _, 

I — I Place Trauma Occuned 



D 



Name of Police Force Informed 

Dist. 6. 



This woman was found in her apartment unconscious 
and unresponsive at 2350 hrs July 20th 19-36. Police transferred 
^ to V< ctoria Hosrital where she was pronounced dead at 0055 h^s 
some 15 mins after her arrival. Police also found a suicide note 
at the acartment. Autopsy revealed no anatomical cause of death. 
Toxicolosv results were made available to me Jan. 9th 1937. 



J. S . Garwood 



^ # ^ aJ , „ww^. A MEDICAL EXAMNER FOR THE PROVINCE OF MANrTOBA, APPOINTED UNDER THE FATAUTY ilMQUSRIES ACT, DO 

' ™ "irT^fcnAvm: , T Tihv 19_S£h. D TAKE CHARGE OF KiKilSSfi * THE BODY OF P &^terS _ , 

CERTIFY THAT I DID ON THE _2JL£H DAY OF ^BXJL « JilXD.TAKE CH^ ^ ^ cn « OPiTH AND THAT A FACTsV™^ H^EIN REGARDING THE 



IN.ORMEDTHE POUCH AND MADE ALL REASONABLE iNVESTtGATlONS TO ASCERTAIN THECAL AND MANNER OF DEATH ANDTHAT 
DEATH ARE THUS AMD CORRECT TO THE BEST OF MY KNOWLEDGE AND BELIEF. 



» ,F body not viewed, state reason: Well documented suicide. 




ArrtnL^ 



Signature of Medical Exalt 

- . 'Jan. l@th 1937 



Date 



Manitoba 
Attorney General 



<£r 



Office of the Chief Medical Examiner 

AUTOPSY REPORT FORM 



File no. 



for Office Use Only 



Nsime of Deceased 
Home Address — 



-JSE 



$£$$- 



PHYLLIS - 



Hospital Autopsy No. 8&. -V h 6 

Preliminary Report L9> Final Rerjort D 

(Christian Names) 



. Sex _J[ Age JIL 




(Surname) 

206-3030 PEMBINA HwY. WINNIPEG, MANITOBA p, ace of Death 206-3030 PEMBINA HYW WINNIP EG 



Date and Time of Admission . 
Date and Time Pronounced . 
Name of Poiice Department . 



0040 hrs 



0055 hrs 



86 07 21 

(if applicable) 

86 07 21 



Place of Autopsy 



•VICTORIA GENERAL HOSP. 



WINNIPEG DISTRICT ff6 



Date and Time of Autopsy 0800 hrs 86 07 22 
Name of Medical Examiner PR a J * 5, GARWOOD 



NARRATIVE SUMMARY OF FINDINGS RELATED TO DEATH: (Include only relevant history, laboratory and anatomical findings) 




FROM THE WINNIPEG POLICE DISTRICT #6 



Found in her bedroom with face down, fully clothed. Rigor mortis already present* 
Apartment door locked with deadbolt in place. Had 
"suicide note and will"<. 

Past history (Victoria General Hospital # 24e748 » admitted 
to Psychiatry from 86 02 17 to 86 03 03 with major 
affective disorder, depression,, 

Had hysterectomy in 1984 

Wote: Toxicology results pendings. 



Reports 


Outstanding 


Enclosed 


Alcohol 


X@ 


□ 


Drugs/Poisons }j§$ 


□ 


CoHb 


a. ■ 


n_ T 


Microscopy 


A 


D-' 


X-Ray 


□ 


' CX-. 


Microbiology 


□ 


a , 


RCMP 


LAB 






Name of Lab 








•v 



1 CAUSE OF DEA TH FOR MEDICAL CERTIFICATE OF DEATH (if pending, say why) 

j- DUE TO or as a consequence of 



Parti 

Immediate Cause of Death 

Antecedent Causes, If Any, 
Giving Rise tc the Immediate 
Cause (a) Above, Stating the 
Underlying Cause Last. 



(a) 



(b) 



(c) 



DUE TO or as a consequence of 



Partll 

Other Significant Conditions 
Contributing to the Death But 
Not Causally Related to the 
Immediate Cause (a) Above. 



BILATERAL PULMONARY CONGESTION 



Is it likely that outstanding toxicology or microscopic reports may alter the Medical Cause of Death? Yes ^ No D 



DATED at _ 
22 



WINNIPEG 



PATHOLOGIST. 



DR. S,w'>CHANG M.Bo 



(type or print name) 



. day of . 



JULY 



A.D. 19-86 



MG-59/Rov. 34 



Pathologist to retain Goldenrod copy (for personal um only) and forward. 
alt remaining c opies to the Office of the Chief Medical Examiner, 120—770 
Bannatyne Avenue, Winnipeg, Manitoba. B3E 0W3 




FORENSIC * 

LABORATORY REPORT /' 

THIS REPORT OR ANY RELATED 
PHOTOGRAPHIC OR OTHER MATERIAL 
MAY NOT BE PUBLISHED, IN WHOLE 
OR IN PART, WITHOUT THE WRITTEN 
CONSENT OF THE COMMISSIONER 
OF THE ROYAL CANADIAN 
MOUNTED POLICE. 



IPPORT DES LABORATOIRBS 
.JDICIAMES 

IL EST INTERDIT DE PUBLIER £% TOUT'oO L 
EN PARTIE CE RAPPORT OU TOUTE DOCUMEN- 
TATION PHOTOGRAPHIQUE OU AUTRE 
S'Y RAPPORTANT SANS LE CONSENTEMENT ' 
PAR ECRIT DU COMMiSSAIRE 0£_LA .-"-■ 
GENDARMERIE ROYALE DU CANADA-- ,.,' - 



GATE 



security classification, 
classification securitaire 



86.12.30 



LAB, RLE NO. ■ DOSSIER OU LAS. /V" 

FLW 86-772 



YOUR FILE No. . VOTRE DOSSIER N" 

86/6/135007 



TO -A 



The Chief Medical Examiner's Office 
120 - 770 Bannatyne Avenue 
WINNIPEG, MB- R3£ 0W3 

ATTN: R. MATTOCKS, RN, MEI 



Toxicology Section 
Forensic Laboratory 
R.C.M. Police 
621 Academy Road 
WINNIPEG, MB- R3N 0E7 



REFERENCE ■ REFERENCE 

Phyllis PETERS (BD: 11.07.49) 
206 - 3030 Pembina Hwy. 
WINNIPEG, MB. (DOD: July 21/86) 



Pathologist : 



Dr. Chan 
Victoria General 
Hospital 



COPIES to ■ COPIES A 



Chief of Police, Winnipeg Police Department 



GENERAL, : 



The following exhibits were received personally from 
R.B. MATTOCKS, RN , MEI, at the Forensic Laboratory, 
Winnipeg, Manitoba, on 86.07.22: 



Exhibit IB 
Exhibit 4 
Exhibit 5 
Exhibit 6 



one vial of blood 

one container of liver sample 

one container of kidney 

one container of gastric contends 



The following exhibits were received personally from 
C/M A. Kraut, Alcohol Section, on 86.10.10: 



Exhibit 1A 
Exhibit 2 
Exhibit 3 



one vial of blood 

two vials of vitreous humor 

one vial of urine 



PURPOSE: 



1) To examine Exhibits 4 (liver) and 6 (gastric contenrs ) 
for the presence of common drugs (eg. amphetamines, 
barbiturates, narcotics, salicylates, tranquillizers, 
etc.) and poisons (eg. strychnine, warfarin, etc.). 

2) To examine Exhibit IB (blood) for the presence of 
benzodiazepines (eg. diazepam-Valium) . 

3) To examine Exhibit 3 (urine) for the presence of . 
acetaminophen, ethchlorvynol , phenothiazines and 
salicylates. 



To quantify Exhibit IB (blood) for amitriptyline 



2 




/2 



IRCMPGRCI 



ROYAL CANADIAN MOUNTED POLICE • GENDARMERIE ROYALE DU CANADA 



CanadS 



FORENSIC 
ffflffORATORY REPORT 



REPORT DES LABORATOIRES 
JUDICIAIRES 



REFERENCE - REFERENCE 

Phyllis PETERS 



SECURITY CLASSIFICATION 

classifica now szcufiirAttie 



PAGE 



OF 



LAB FILE NO - OOSSIErt DU lAB ,v° 

FLW 86-772 



3. RESULTS : 
Purpose 
(1) 



(2) 
(3) 
(4) 



Exhibit 



4 {liver) 



Drug 



caffeine 
amitriptyline 
nortriptyline 
chlordiazepoxide 
6 (stomach contents) amitriptyline 
IB (blood) negative 

3 (urine) negative 

IB (blood) amitriptyline 



Level 



Comments 



not quantified 



approx. 2mg% lethal 



4. REMARKS: 



1) Amitriptyline is an antidepressant used to relieve 
anxiety. Nortriptyline, a metabolite (body-breakdown 
product) of amitriptyline is also an active antidepressant. 

2) Chlordiazepoxide is an antianxiety agent used to relieve 
tension. 



DISPOSITION 
OF EXHIBITS: 



1) The exhibits are being held pending personal pickup. 

2) Exhibit Disposition form to follow. 



SUBMITTED BY: 

T.A. Krepiakevich, B.Sc. (PHARM) , M.Sc. 
Toxicology Section 




RCMPGfiC 



ROYAL CANADIAN MOUNTED POLICE - GENDARMERIE ftOYALE DU CANADA 



Canada 



Affidavit of George Bergen 

Sworn this 5 f ~~ day of May, 1996 



George Bergen 
150 Dorge Drive 
Winnipeg, MB. R3V 1M4 

Telephone: 204-261-4382 (home) 
204-982-6432 (office) 



AFFIDAVIT O^ C.F.OROE BERGEN 

I, George Bergen, of the City of Winnipeg in the Province of MANITOBA 

MAKE OATH AND SAY AS FOLLOWS: 

1 . That I am employed in the city of Winnipeg, a homeowner and a single parent of two 
dependent children, namely Paul Bergen age 22, and Andrew Bergen, age 16, both of 
whom live with me at 150 Dorge Drive in the City of Winnipeg. 

2. That I graduated from the University of Winnipeg in the Province of Manitoba earning 
a Bachelor of Science degree in i 97 1 . 

3. That I am the estranged husband of Bonnie Joan Bergen(nee Peters) who in November 
of 1992, became mentally disoriented after undergoing memory recovery/multiple 
personality disorder(MPD) diagnostic therapy at the Winnipeg Christian Counseling 
Group, an agency of the Grant Memorial Baptist Church. 

4. That Bonnie Joan Bergenfnee Peters) my estranged wife, due of the affects of the 
memory recovery/MPD diagnostic therapy, was effective in 1994 placed on permanent 
mental disability allowance in the City of Winnipeg. 

5. That I am the brother -in -law of Phyllis Peters(Bonnie's sister) who(Phyllis) became 
deceased at the age of thirty-nine(39) on July 20, 1986, while under the care of one Dr. 
Colin A. Ross at the University of Manitoba. 

6. That Phyllis Peters, at the time of her death, resided within a five(5) minute car ride 
from my family's residence at 150 Dorge drive, in the City of Winnipeg and that Phyllis 
Peters had a close family relationship with my family members. 



7. That at the time of her death, Phyllis Peters had been employed full time at the 
Manitoba Medical Association in the City of Winnipeg for about three(3) years as a 
computer operator. 

8. That in the fall of 1985, Phyllis Peters then thirty-eight(38) years of age, commenced a 
therapeutic counseling program at the University of Manitoba anxiety disorder clinic, a 
clinic that was under the sole direction of one Dr. Colin A. Ross as given in Dr. Ross's 
sworn testimony on July 24, 1995, and which transcript is attached to this Affidavit as 
evidence. 

9. That after Phyllis Peters commenced therapeutic counseling at the University of 
Manitoba, her(Phyllis's) condition deteriorated rapidly and she began taking large 
amounts of psychiatric medication prescribed to her. 

10. That by mid-February, 1986, Phyllis Peters' condition had deteriorated dramatically 
and she was hospitalized at the Victoria General Hospital psychiatric ward for a two(2) 
week period. 

1 1 . That by April 1 986, Phyllis Peters was experiencing great difficulty at her place of 
employment with the Manitoba Medical Association at which time she(Phyllis) began 
seeking my advise in labour/management matters. 

12. That in June of 1986, Phyllis Peters asked me to intervene as her representative in 
dealing with her employer at her place of employment. 



13. That since t was somewhat acquainted with the Executive Director of the Manitoba 
Medical Association John Laplume, I agreed to assist her(Phytfis) on the condition that 
she explain her work relationship to me in great detail in order for me to get at the root of 
the difficulties she(Phyllis) was experiencing at her place of employment. 

14. That in June 1986, Phyllis Peters began recounting to me the effects of her 
medications and that she was experiencing terrible satanic and devil worship nightmares, 
and that she was having memories of childhood satanic abuse flashbacks. 

15. That in July 1986, on at least two occasions, Phyllis Peters advised me that she 
thought that she(Phyllis) was going crazy, and when I asked her why she had these 
thoughts, Phyllis began to recount that she had different personalities and that sometimes 
she no longer knew what kind of person she was. 

16. That by mid- July, 1986, 1 knew that Phyllis Peters' employment difficulties were the 
result of large amounts of psychiatric medication and childhood satanic memories and 
ever recurring nightmares that seemed to come from her therapy sessions at the 
University of Manitoba. 

17. That on July 20, 1986, Phyllis Peters could no longer cope with the large dosages of 
drugs and the terrible satanic memories induced in the counseling she was receiving at the 
University of Manitoba anxiety disorder clinic, and she took an overdose of medication 
that had been prescribed to her and she died. 

18. That on or about November 2, 1995, 1, George Bergen, after reading the July 24, 1995 
sworn testimony of Dr. Coiin A. Ross given in a state of Minnesota court, became aware 
that Phyllis Peters had been under the care of Dr. Colin A. Ross before and at the time of 
her death at the age of thirty-nine(39). 



19. That the research material compiled and filed with this Affidavit, I believe provides 
compelling evidence that Dr. Colin A. Ross induced Phyllis Peters to involuntarily 
commit suicide by, 1) fraudulent therapy and, 2) by providing her(Phyllis Peters) with die 
motivation and the means to end her life. 

20. That it is my belief that the evidence provided along with this Affidavit warrants a 
criminal investigation of one Dr. Colin A. Ross. 

I George Bergen, do solemnly and sincerely affirm that the contents of this affidavit, 
made and subscribed by me George Bergen are true. 



Sworn before me at the City 
of Winnipeg, in the Province of 
Manitoba, this_3/sf~ day of 
May,A.D., 1996 

Jan Malanowich 




Tn?Js?^^/c £- 



Commissioner of Oaths, for the Province of 
Manitoba. My Commission expires on 



Deponent: 
George>Bergen / 



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IS 

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STATE OF MINNESOTA 
COUNTY OF RAMSEY 



" - DISTRICT COURT 

SECOND JUDICIAL DISTRICT 

File No. C4-94-203 



Vynnette Ann Hamanne, 
Kenneth Earl Hamanne, 
Adeana Ruth Hamanne, 



Plaintiffs, 



vs . 



PARTIAL TRANSCRIPT 
OF PROCEEDINGS 



Diane Bay Humenansky, M.D., 

Defendant . 

The above-entitled matter came duly on for trial before 
the Honorable Bertrand Poritsky, Judge'.of District Court, on 
the 30th day of June, 19 95, in Room '13 80 of the Ramsey 
County 'Courthouse , in the City of St. Paul, State of 
Minnesota. 

APPEARANCES : 

Edward Glennon, Esq., R. Christopher Harden, Esq., and 
Christopher H. Yetka, Esq., appeared on behalf of _ Plaintiff s 
Vynnette Ann Hamanne, Kenneth Earl Hamanne, and Adeana Ruth 

Hamanne . 

David Waxman, Esq., and Eric We in/ Esq./ appeared on 
behalf of Defendant, Diane Bay Humenansky. 

********** 



25 



1 


w 


T T N E S S 


_ I. 


N D E X 








2 ". 


■ 1? 


JULY 24, 


1395, 






CI 




3 • 
4 


CALLED TO TESTIFY ON 
BEHALF OF DEFENDANT 
REGARDING THE 
FRYR-DAURRRT ISSUES: 
















5 
6 

7 
8 
9 


nn rOT.TN ROSS 

(Outside presence 
Examination - Mr. 
Examination - Mr. 
Examination - Mr. 
Examination - Mr. 
Examination - Mr. 
Examination - Mr. 


of jury) 
Waxman 
Barden 
Waxman 

Barden 
Waxman 
Barden 








IS 
48 
SO 
66 
11 
11 






10 


* 


* * 




* 


* 








11 
12 


CALLED TO TESTIFY ON 
RRKALF ™? DEFENDANT: 


ury) 
lan 








86 


C 




13 


TIP. COLIN ROSS 




14 


(In presence of j 
Direct - Mr. Waxro 




15 ■ 


* 


* * 




* 


* 








16 


















17 


.: ; . . . - 
















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2S 














c 





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(July 24. 1995) 



(Aporox. 1:30 p.m.) 



WHEREUPON, the following proceedings were duly had:' 

(Appearances: As previously indicated, excluding 

Ms . Davy . ) 

(The following proceedings were had in chambers. 

Robert Kuderer, Esq., also present in chambers.) 

THE COURT: The record should reflect the fact 
that I'm present in chambers with the three attorneys who 
appeared on behalf of the Plaintiffs in the Hamanne case and 
the two attorneys on behalf of the defense, Mr. Waxman and 
Mr. Wein. 

THE COURT: We've just briefly discussed 
scheduling. Mr. Kuderer now also showed up on behalf of the 
insurers. We've just discussed scheduling this afternoon. 
And at this point we've concluded that Mr. Glennon would 
like to make a statement for the record. He made an offer 
of proof -- not offer of proof, but he's outlined what he 
would say. I'd like to put that on the record now. If 
anybody wishes to respond, they may. 

MR. GLENNON: On Friday at one o'clock or 
thereabouts when we had a telephone conference with Ms. 
Lehr, who, as I understand it, is chief counsel for the 
Minnesota Court of Appeals, she was getting background 
information from the lawyers for the parties about the 
position -- each one's position -- with respect to the 



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IS 
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MR. WAXMAN: 166 is in, for the record? 



THE COURT: Yes. 



19 



(' 



BY MR. WAXMAN: 

Q. Would you briefly describe your educational background? 

A. I completed my M.D, my medical degree, at the University of 
Alberta in Edmonton in Canada in 1981. I moved to the 
University of Manitoba in Winnipeg and completed my 
psychiatry training there in 1985. And got the Canadian 
equivalent of a specialty in psychiatry. 
You were born and raised in Canada? 



Q. 
A. 

Q. 

A. 
Q. 

A. 



Yes, true. 

You went to Canada for your undergraduate and post-graduate 

studies? { 

Correct . 

Subsequently to completing your education, you indicated 

that you completed a residency in psychiatry as well? 

Correct .' 



Q. That was in Canada? 

A. Correct. 

Q. You completed that successfully? 

A. Correct. 

Q. Thereafter, did you engage in the practice of psychiatry? 

A. I finished in the end of June 1985 and immediately went on 
staff as a first assistant, then associate professor of t 

K 

psychiatry at the University of Manitoba. I worked there 



1 

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s* 







>• 



/V 



i;./" 1 



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9^ 

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A. 




13 
4 



J^ r "' 15 



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-r 



Q. 



A. 



__20 

until the end of October 1991 doing a combination of 
inpatient and outpatient work, teaching and research. 
What was the nature of your practice at the University of 
Manitoba? 

It evolved. It started off half time general adult 
inpatient work, which means basically people coming through 
the emergency department with all kinds of different 
psychiatric diagnoses, and receiving acute care. And half 
time director of the anxiety disorders clinic. 

Then in 1988 I stopped the anxiety disorders clinic 
half and started a dissociative disorders clinic. And 
basically followed that pattern until the last nine months 
before I left in late '91, I did solely outpatient 
dissociative disorders work, which included clinical 
service, teaching, research. 

What was the nature of your research at the University of 
Manitoba? 

There's several different types of research I did inside the 
dissociative disorders field and outside the dissociative 
disorders field, both. I had a number -- this is all 
reflected in my C.V. I did a number of drug company 
contracts, which means there is a drug that isn't yet on the 
market that a drug company is developing, and in the United 
States the Federal Drug Administration, in Canada the Health 
Protector Branch, mandates by law that there is a large 




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_22 

doesn't exist just by itself. Some research on the 
financial cost of failure to make the diagnosis and the 
financial cost of making the diagnosis and providing 
treatment for multiple personality disorder. That's kind of 
a general overview of the research I did. 
Doctor, at the University of Manitoba did you have a 
position of responsibility or a leadership position in the 
dissociative disorder service? 

Just at the University? I was the director of the 
-<* dissociative disorders program there. 
You ran the program there? 

Calling it a program really exaggerates it a bit. Basically 
it consisted of me, a research nurse, a half-time social 
worker, some of the time a resident, and some research 
assistants and medical students doing research. It wasn't a 
full, big clinic. 

Okay. Compare that, if you will, with the environment in 
which you currently work now? 

I moved from Winnipeg to Dallas late October, early 
November, '91. The purpose of the move, besides just 
personal reasons, like the weather is better, was basically- 
professionally I couldn't function in the way I wanted to in 
Canada. I couldn't set up a full unit that was in a 
separate physical location that had specialty staff 
dedicated to it that would allow me to treat any kind of 



91 



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a 

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Q. 

A. 



^.%^r ' ia 



Q. 
A. 

Q. 
A. 






Q. 




It' a essentially a catch-all diagnosis? 

i 
It's a catch-all, but there are several sub-types that are 

defined. One example is cases of dissociative identity- 
disorder where the identity states are not fully separate 
and crystalized out. 

These are all contained in the DSM, correct? 
Correct . 

And who is the DSM published by? 

American Psychiatric Press, which is the publishing arm of 
the American Psychiatric Association. No. No. That's not 
right. It's actually published directly by the American 
Psychiatric Association. 

The America Psychiatric Association? V 

Right. The reason I made that mistake is most of the 
publications are through the American Psychiatric Press, 
which is an arm of the American Psychiatric Association. 
Doctor, did you have any leadership or administrative 
positions while you were in Canada? 

Well, I was a professor in the department of psychiatry, 
which is a leadership position by itself. I was director of 
the anxiety disorders clinic. Director of the dissociative 
disorders clinic. Acting medical director of one of the 
inpatient units for awhile. And was on the medical staff. 
That's administrative leadership. Then I had a research an^- 
teaching and reputation kind of leadership position. 



5< 




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— JLL 

suburbs of Dallas. Richardson is where my private office 
is, and Piano is where the hospital I practice is. 

q. It doesn't sound like a Texas accent. Where were you born 
and raised? 

A. Just a little north of the Texas border in Canada. 

Q. Okay. Where was it that you were educated, Sir? 

A. I did my medical school work in Edmonton at the University 
of Alberta. I got my M.D. degree in 1981. Then I moved to 
Winnipeg and did my psychiatry training. Got my Canadian 
certification in psychiatry as a specialist in 1985. 

Q. After you finished your training in 1985, did you engage in 

the practice of psychiatry? 
A. The academic year ends at the end of June. I finished my 
training at the end of June. Beginning of July of '85 I 
became what is called an assistant and later associate 
professor of psychiatry- I split my time basically in terms 
\M ' 17 ^""^ of the clinical part between general adult inpatient 

_8 psychiatry, which means people come in through the emergency 

19 department with any kind of psychiatric disorder, and half 

20 J-4 time in an anxiety disorders clinic. Then I did teaching 

21 and research and academic work 



22 
23 
24 
25 



Q. And in what areas did you do teaching, research, and 

academic work? 
A. I did a smattering of research and teaching in quite a few 

different areas of psychiatry. What is called drug studies, 



AFFIDAVIT 
Re: Dr. Colin A. Ross 

Affidavit of Robert Alexander Cowan 

I, ROBERT ALEXANDER COWAN, of the City of Winnipeg in the Province of MANITOBA, 
CANADA, was employed as a Director in Mental Health for the Government of Manitoba from 
1989 to 1996, MAKE OATH AND SAY: 

1 . That from 1989 to 1996, I, Robert Alexander Cowan, met with and attended meetings 
with senior administrative staff at the St. Boniface General Hospital and met with some 
members on the Board of Directors of the St. Boniface General Hospital. 

2. That from 1989 to 1996 I, Robert Alexander Cowan, discussed confidential 

and other hospital matters with members of the Sisters of Charity (The Grey 
Nuns), who where and are the proprietors of the St. Boniface General Hospital having 
representation on the Hospital's Board of Directors. 

3. That inl991 I, Robert Alexander Cowan, was aware of or it was my understanding that 
Dr. Colin A. Ross did not leave his (Ross's) employment at the St Boniface General 
Hospital on a voluntarily basis. 

4. That in 1 991 I, Robert Cowan, and senior Management in the Department of Health for 

— continued — 



the Government of Manitoba believed that Dr. Ross's 1991 involuntary 
termination from his employment at the St. Boniface Hospital was not made public 
and that Dr. Ross was allowed to resign in a manner to make it publicly appear as a 
voluntary resignation. 

I, ROBERT ALEXANDER COWAN, do solemnly affirm that the contents of this AFFIDAVIT 
to be true. 



SWORN before me 
in the City of Winnipeg, 
in the Province of 
Manitoba, CANADA. 
On ^ff ,1998 AD. 

Commissioner* of Oaths. 
My Commission expires 
on TTl/yvX>(> , 2000 A.D. 




toBert Alexander Co^Wan (deponent] 



150 Dorge Drive 
Winnipeg, MB, R3V 1M4 

June 20, 1998 

Sister Jacqueline St. Yves, s.g.m., Mauson de Mere D'Youville, 138 Rue St. Pierre, Momtreal 

Que. H2Y 2L7 

Sister Gabrielle Cloutier, s.g.m., Centre Youville, 845 Dakota St. Winnipeg, MB. R3M 5M3 

Sister Jean Ell, s..g..m„ Sara Riel Inc., 210 Kenny St. Winnipeg, MB. R2H 2E4 

Sister Germaine Hetu, s.g.m., 151 Despins St. Winnipeg, MB. R2H 0L7 

Re: Dr. Colin A. Ross 

Dear Sisters, 

This is further to my last letter to you of June 12, 1998, 

I am writing to offer my assistance to you or the Catholic Church in dealing with the residential schools 
issue. This I did not do in my last letter to you. 

In the past few years I have investigated ten cases where Manitoba social workers and therapist have 
implanted fales memories of sex and/or satanic cult abuse in vulnerable clients by suggesting that thier 
emotional, relationships, or mental health problems are caused by childhood abuse. Manitoba has many 
therapists who were (and some still are) followers of Colin Ross, and they (social workers and therapists) 
have done great damage to families, the Catholic and Anglican Churches in Canada, 

You should know that I am employed by the Manitoba Government Employees' Union as a Senior 
Research Officer in my daily line of work, and you may call me at my office or at home at anytime. My 
office number is 204-982-6432 and my home number is 204-261-4382. 

I am forwarding a list of book titles on this subject matter as well as a list of eminent psychiatrists. Please 
feel free to call them (psychiatrists) if you require references about the writer. Most of them 
(psychiatrists) know me from letters or telephone contacts. For references please also feel free to ask 
anyone you feel may know of me. In my line of work I get to know many people. 

I am also forwarding 'yet a nother' recent newspaper clipping that makes false and uncorroborated 
allegations against the Churches. I suppose some might rationalize this whole issue by pointing out that 
Christ too was subjected to many false allegations and leave it at that. Obviously I myself am not so 
inclined, 

I would be prepared to attend meetings and/or provide you with any addituional information 
that you may require. 

I would feel blessed if I could be of some assistance to you at this time. 
Sincerely, 




George Bergen, B.S 



ROOKS ON FALSE MEMQRTES PRODUCED TN THERAPY 



1 , Victums of Memories: Incest Accusations and Shattered Lives; Mark Pendergrast; 

Published by Upper Access Books (1996). 

2 Making Monsters: False Memory Psychotherapy and Sexual Abuse; Richard 

Ofshe & and Ethan Waters; Published by Charles Scribers and Sons (1994). 

3 . Manufacturing Victums: What the Psychology Industry is Doing to People; Tana 
Dineen; Published by T. Robert Davies Publishing (1997). 

4. Spectral Eviedence: The Ramona Case; M. Johnson; Published by Houghton 
Mifflin (1997). 

5 Psychology Astray: Fallacies in Studies of Repressed Memory and Childhood 

Trauma; Harrison Pope Jr., (Harvard); Published by Upton Books (1997). 

6. Hoax and Reality: The Bizzare world of Multiple Personality Dissorder; Dr. 
August Piper Jr. Published by Jakson Arnason Inc. (1997). 

7. Myth of Repressed Memory; Elizabeth Loftus & K. Ketcham; Published bjt 9L 
Martin's Press (1994). 

8. Return of the Furies: Analysis of Recovered Memory Therapy; Wakefield & 
Underwager; Published by Open Court Publishing (1994). 

9. Last Thoughts: Understanding the False Memory Crisis and How it Could Affect 
You; P. Simpson; Published by Thomas Publishing (1997). 

10. Lost Daughters: Recovered Memory Therapy and the People it Hurts; K Van- Til;, 
Published by Wm. B. Erdman's Publishing (1997). 



Authorities in Psychiatry or Psychology Familiar 
with Dr. Colin A. Ross's Medical Practise 



Dr Peter Hays, University of Alberta Hospital, Department of psychia try, 
Rni 1E7 3 1 The Walter MacKenzie Centre, 84404 12 Street, Edmonton, 
Alta. T6G 2B7, ( Dr. Hays is Vice- chairperson of the department) 
Tel: 403-492-6599 ' 



Dr Harold Merskey, London Psychiatric Hospital, 350 Highbury Avenue, 
PO Box 2532, London ON. Tel: 5i9-455-5U0.(Dr. Merskey is one of 
Canada's leading pychiatrist, trained in England) 

Dr. Harrison Pope Jr., Associate ^'i*^'^^ ^ 
The McLean Hospital, 115 Mill Street, Belmont, MA. Tel. 617-855 2911. 

Dr Richard Ofshe, Professor at Berkeley and a Pulitzer prize winner, 7112 Marlboro 
Terrace Berkeley, CA. 94705, Tel: 5 10-845-491 1 . 

Dr. August Piper, 901 Boren #701 Seattle WA. 98104, Tel: 206-623-5757 

Dr Christopher Barden, (Phd. in Psychology and Attorney at Law) 4025 Quacker Lane 
North, Plymouth, MN. 55441, 612-595-0556. 



Dr. John 



Hochman, 6345 BalboaBlvd. Bidg. 3, Ste. 255, Encino CA. 91316. 



<(j 



Dr Jonathan Werier, 205-2265 Pembina Hwy. Winnipeg MB. Tel: 2^4-261-9761. 
( Dr. Wericr is a family physician practising in Winnipeg) 



1 50 Dorge Drive 
Winnipeg, MB. R3V 1M4 

June 12, 1998 

Sister Jacqueline St. Yves, s.g.m., Mauson de Mere D'Youville, 138 Rue St. Pierre, Momtreal, 

Que. H2Y 2L7 

Sister Gabrielle Cloutier, s.g.m., Centre Youville, 845 Dakota St. Winnipeg, MB. R3M 5M3 

Sister Jean Ell, s..g..m., Sara Riel Inc., 210 Kenny St. Winnipeg, MB. R2H 2E4 

Sister Germaine Hetu, s.g.m., 151 Despins St. Winnipeg, MB. R2H 0L7 



Re: Dr. Colin A. Ross 
Dear Sisters, 

I write to you with a single purpose. To be ofassistance to the thousands of innocent victims 
who have fallen prey to what is surely the biggest scandal of the twentieth century. These innocent 
victims (including two members of my own family) have fallen prey to falsely implanted 
memories that have in turn generated false allegations of sexual abuse, rape, incest and satanic cult 
abuse. The innocent victims of these false allegations include thousands of Priests, Nuns, fathers, 
brothers, sisters and other relatives. 

The Priests and Nuns who gave the best part of thier lives to help the disadvantaged people of 
North America over the past 200 years are now falsely branded in the media as sex abusers and 
perverts. I am of course talking about the residential schools issue. Even governments have bought 
into believing this scandal to be true. According to media reports, there are now more than a 
thousand lawsuits on sexual and physical abuse outstanding against the Catholic and Anglican 
churches involving residential schools. And Canadian governments are preparing for an out of 
court settlement to 'payoff those that are making the false allegations of sexual abuse which 
allegedly occurred at these schools. Such a payoff would forever leave a taint on the Church. This 
is not to say that there was no abuse whatsoever. There are always exceptions. 

Since 1993 The False Memory Syndrome Foundation of Phladelphia has logged over 20,000 
(Canada & the US) cases were one or more family member(s) has falsely accused other family 
member(s) of sexual abuse. These false allegations come after a client has gone to a memory 
recovery therapist who attributes the client's emotional and mental health problems to childhood 
incest and other crimes within the family. And where a member from an aboriginal group goes to 
a memory recovery therapist, the emotional and mental health problems of a client are attributed 
to being sexually abused by Priests and Nuns if the client attended a residential school during his 
or her childhood. 

At the center of this contraversy stands Dr. Colin Ross, who was empolyed at the St.Boniface 
Hospital from 1985 to 1991 practising fraudulent and very destructive medicine. Ross was also a 
Professor at the University of Manitoba. Being an M.D., a University Professor, young and 
charismatic, Ross had an enormous infuence in Manitoba and indeed throughout North America 
in the field of psychiatry, social work and especially christian therapy techniques, preaching his 
fraudulent therapy to thousnds at seminars and speaking engagements from 1985 to 1996. From 
the onset in 1985 at the St. Boniface Hospital, Ross threw himself into using a pop form of 
therapy based on the books Sybil and Three Faces of Eve, that were made into Hollywood movies 
in the late 1970's and ealy 1980's. 



Ross quickly became popular with feminists and fundamental christians. Feminists said that 
Ross's new found insite into the human condition proved that the patriarchal family was corrupt 
and evil, while fundamentalists believed here was a medical doctor who had found the devils 
footprints. Note the mass public hysteria Ross generated in 1991 in the City of Winnipeg, (see 
enclosed documents). 

Although he had no medical evidence, Ross held that virtually all forms of emotional and mental 
health problems stemmed from the patient having been sexually abused in childhood. And if the 
patient didn't have any memories of abuse, Ross would say that the patient had repressed or 
became amnesiac to these alleged traumatic events which usually involved incest and/or satanic 
cult abuse within the family. To help his patients 'recover memories' Ross would hypnotize and/or 
inject his patients with sodium amytal and then proceed to 'call out the different alters' that 
allegedly held the forgotten abuse memories. Because his patients had these alters, would Ross 
fraudulently diagnosed his patients as having Multiple Personality Disorder (MPD). My family 
doctor calls Ross a "total fraud" and that he (Ross) has created "cult like" following. 

In his 1994 book The Osiris Complex (p. 130j Ross describes how he preformed a demonic 
exorcism at the St. Boniface General Hospital after members from the church say a prayer. 

It is my belief that between 1985 and 1991 there where five suicides linked directly or indirectly 
to Ross or his therapy through the work of those Ross had trained. My sister-in-law was one of 
these five. The damage caused by this man cannot be exaggerated in my view, and I do not 
believe that Ross left the St. Boniface Hospital in 1991 on a voluntary basis. I agree with sister 
Ell, that Ross did not leave on a voluntary basis. I do not believe that the Sisters of Charity 'Grey 
Nuns' would allow Ross to practice his fraudulent and dangerous medicine even if the Hospital 
Administration wanted him to continue. 

A former patient of Ross at the St. Boniface Hospital, Roma Hart, who is currently sueing him, 
calls Ross a Madman. The writer and Hart have both complained to the College of Physicians and 
Surgeons, however, the College is protecting him. 

As you can see from the letter to the writer dated May 15, 1998, Dr. Colin Ross will soon be 
served with an inditment in the THE DISTRICT COURT of DALLAS COUNTY, Texas. The 
writer may be a witness at trial. 

I am also forwarding other documents that are self explanitory to this matter. This includes the 
letter to me from The President of the St Boniface General Hospital, Mr. Ken Trembly dated May 
20, 1998. It is my understanding that Mr. Trembly has been terminated since writing this letter, 
Mr. Trembly's letter appears tantamount to admitting there was 'a cover-up' in 1991 when Ross 
left the employ of the St. Boniface Hospital. 

Please confirm, as soon as possible, if in your view Dr. Colin Ross terminated voluntarily or 
involuntarily from his contract of employment at the St Boniface Hospital in the fall of 1991. 
Your answer will be very important to the Grey Nuns, the Church, the Hospital. 

Thank you in anticipation of your reply. 
Sincerely, ,n 



J ]^H 



p^f^ 



COPY 



i 

2 

3 

4 

5 

6 

7 

8 

9 

10 

1 1 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 



STATE OF MINNESOTA 
COUNTY OF RAMSEY 



Vynnette Ann Hamanne, 
Kenneth Earl Hamanne, 
Adeana Ruth Hamanne, 



IN DISTRICT COURT 

SECOND JUDICIAL DISTRICT 

File No. C4-94-2Q3 



Plaintiffs, 



vs 



Diane Bay Humenansky, M.D., 

Defendant. 
******************************** 

TRANSCRIPT OF PROCEEDINGS 
******************************** 
The above-entitled matter came on for hearing 
before the Honorable Bertrand Poritsky, Judge of District 
Court, on the 2Sth day of July, 1995, at the Ramsey County 
Courthouse, Room 1380, St. Paul, Minnesota, commencing at 
approximately 9:00 o'clock a.m.; 

The defendant appeared through her attorneys, David 
waxman, Esq., Eric Wein, Esq., 120 South Riverside Plaze, 
Suite 1200, Chicago, Illinois; and the plaintiffs appeared 
through their attorneys, Edward Glennon, Esq., R. 
Christopher Barden, Esq., and Christopher H. Yetka, Esq., 
.4200 ID Center, 80 South Eighth Street, Minneapolis, 
Minnesota, at said time and place the following proceeding 
were had: 



1 




INDEX 


2 






3 


WITNESS: 


DIRECT 


4 






5 


Dr. Colin Ross 


WA-3 


6 






7 






8 


WA = Mr. Waxman 




9 


B = Mr. Barden 




10 






1 1 






12 






13 


EXHIBITS: 


MARKED 


14 






15 


EXH-22 


38 


16 


EXH-167 


41 


17 


EXH-168 


47 


13 


EXH-169 


136 


19 






20 






21 






22 






23 






24 






25 







CROSS 



REDIRECT RECROSS 



B-73 WA-167 B-177 
179 179 



OFFERED 

36 

41 

47 

136 



RECEIVED 

37 

41 

48 

137 



n -i 1 "i "i *-t r 



i *- n. 1 



-i-^i f O 1 *7 



DR. COLIN ROSS 



126 



1 
2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 



Q 



Q 



Do you you use Sodium Amytal in your treatment center? 

MR. WAXMAN: Relevance. 

THE COURT: No. Overruled. 

THE WITNESS: The last time Sodium Amytal was 
used at our treatment center would be within six months of 
my arriving there. And we haven't done one then for three 

and a bit years. 

THE COURT: Which one are you talking about? 

Does that mean before or after your arrival? 

THE WITNESS: The last one done on my unit 
was within six months of my arriving in November of '91. 
in other words, it was early '92. We haven't done one 
since the first half of '92. 

(By Mr. Barden) How about in Canada, when you were 
treating people in Canada, did you use Sodium Amytal 

treatments there? 

I did about roughly 30 Sodium Amytal interviews on patients 

for a variety of different disorders, not just dissociative 

disorders, for a variety of different purposes. 

And were you using Sodium Amytal in those sessions 

specifically to help patients recover so-called lost 

memories or dissociated memories? 

MR. WAXMAN: Relevance. 

THE COURT: No. Overruled. 

THE WITNESS: I've never used Sodium Amytal 



DR. COLIN ROSS 



127 



1 

2 

3 

4 

5 

6 

7 

8 

9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 

23 

24 

25 



Q 
A 



Q 



Q 



A 

Q 



for the purpose of recovering memories. 
(By Mr. Harden) Do you believe in false memories? 
yeah. I believe that there's an abundant — clinical 
evidence and scientific evidence that highly elaborate 
memories can occur in a person's mind when it never 
happened, which is I assume what you mean by false 

memories . 

Do you believe that psychiatrists had an ethical 
professional and legal duty to inform patients of the risks 
and dangers, the Known risks and dangers, of treatment and 

j, u ^f-h- = <-»f alternative treatments before 
of the risk and benefits ot aicernduvc 

the treatment starts? 

That's generally a - generally accepted principle 

throughout medicine with which I agree. 

Bow, you mentioned that you read the discovery from the 

plaintiffs with regard to who the experts would be for the 

plaintiffs and what they would testify to — 

Right. 

_ is that right? Do you remember reading the affidavit of 

Dr. Martin Orne? 

MR. WAXMAN: Objection, Your Honor. Wish to 



be heard 



THE COURT: Yeah. You may approach. 

had at the bench 



(WHEREUPON, a discussion was 
not recorded by the court reporter.) 



PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1 994 and 1 997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost_ 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

ADDRESS BATE 



NAME 



On behalf of over one thousand families who have 
contacted the British False Memory Society to report 
malpractice within the mental health profession and in the 
knowledge of the beliefs and practices of Dr Colin A. Ross, 
we support this petition. 




Director 

British False Memory Society 
Bradford on Avon 
Wiltshire 
United Kingdom 




im 



PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME ADDRESS DATE 

R », fL^ j lit/- lysr/Hje . ^+-A*~fimMA at s^, mg 




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PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

_ N AME ADDRESS DATE 







PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and - 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 



NAME^ a ADDRESS DATE 




fajeA, l^ceV ^V^Ar /_£/£ 



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PETITION 



September, 98 



In July 1993, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in ' 
their childhood by members of then own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 



NAME 




ADDRESS PATE 



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PETITION 



September, 98 



In July 1 998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 




NAME 



ADDRESS 



DATE 



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PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1 994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in '" 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing* therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME ADDRffSg DATE 



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PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas ard 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

ADDRESS DATE 




V7£ 2\/9 



^^^WLsUJ? dg^^cLou 



PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME ADDRESS DATE 

U,Q'^rcuv\aj PH3> <KQ 6jduX& ff \jcMcQ>C 7 act ^ 



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PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg, After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME ADDRESS DATE 



fy /j a ^rr * ft'YKeU ? " c ' 








&)m&a Mnfih <4iJA^n fly^ m^nhti^ fat V^ A (^1 Q*\ }& 



PETITION 



September, 98 



In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 



NAME 



ADDRESS 



DATE 




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PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME ADDRESS ; DATE 



PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 1 years, In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME _ ADDRESS ^ DATE , 

-7^A^4feA/ DJ^- J/3/S 62^9 




PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME ADDRESS _ DATE 



PETITION 



September, 98 



In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 



NAME 



ADDRESS 



DATE 




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PETITION September, 98 

In July 1998 Dr Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsmts 
were also brought against Ross in 1 994 and 1 997 in the Winnipeg Manitoba 
Dr Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted m 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 



NAME 



ADDRESS DAT 5 







PETITION 



September, 98 



In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 



NAME 



ADDRESS 



DATE 







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PETITION 



September, 98 



In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 



NAME 



ADDRESS 



DATE 



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PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME ADDRESS DATE 

^^jf/Z^J^rf' ) vtey &eipjz&£ <srmxj. M^mk f/^tte 



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PETITION September, 98 

In July 1998, Dr. Colin A. Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 

NAME ADDRESS DATE 



PETITION 



September, 98 



In July 1998, Dr. Colin A, Ross was charged with fraud, fraudulent concealment 
and conspiracy to commit fraud in the Dallas County Court of Texas. Lawsuits 
were also brought against Ross in 1994 and 1997 in the Winnipeg Manitoba. 
Dr. Ross has conducted more than 120 seminars across Canada and the US at which 
he taught the same fraudulent therapy that he has been charged with in Dallas and 
Winnipeg. After attending Ross's seminars, many therapists and social workers 
began practicing this fraudulent therapy and began suggesting to their vulnerable 
clients (patients) that they had repressed memories of having been sexually assaulted in 
their childhood by members of their own families or by a Satanic cult. This fraudulent 
therapy has destroyed thousands of families across Canada and the United States and 
is responsible for having caused suicide deaths, many attempted suicides and sending 
innocent family members to prison. This fraudulent 'brainwashing' therapy has cost 
Canadian taxpayers millions of health care dollars over the past 10 years. In the US it 
has cost citizens billions of dollars in terms of health care insurance premiums. 

We the undersigned demand that Dr. Colin A. Ross be brought to justice in Canada 

and the United States of America for crimes against humanity under the Nuremberg Code. 



NAME 



ADDRESS 



~UZ7 



DATE 












ifjiu^h^ * 








1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

IS 

17 

18 

19 

20 

21 

22 

23 

24 



STATE OF MINNESOTA 
COUNTY OF RAMSEY 



" DISTRICT COURT 

SECOND JUDICIAL DISTRICT 

File No. C4-94-203 



Vynnette Ann Hamanne, 
Kenneth Earl Hamanne, 
Adeana Ruth Hamanne, 



Plaintiffs, 



vs . 



PARTIAL TRANSCRIPT 
OF PROCEEDINGS 



Diane Bay Humenansky, M.D., 

Defendant . 

The above-entitled matter came duly on for trial before 
the Honorable Bert rand Poritsky, Judge;., of District Court, on 
the 30th day of June, 1995, in Room' 1380 of the Ramsey 
County "Courthouse, in the City of St. Paul, State of 
Minnesota. 

APPEARANCES : 

Edward Glennon, Esq., R. Christopher Barden, Esq. , and 
Christopher H. Yetka, Esq., appeared on behalf of Plaintiffs 
Vynnette Ann Hamanne, Kenneth Earl Hamanne, and Adeana Ruth 

Hamanne . 

David Waxman, Esq., and Eric Wein; Esq., appeared on 
behalf of Defendant, Diane Bay Humenansky. 

********** 



25 



1 

2 
3 
4 

5 

6 

7 

8 

9 
10 
11 
12 
13 
14 
15 
16 
17 

ia 

19 

20 

21 , 

22 

23 

24 

25 



WITNESS INDEX 

vTXJLY 24, 1995 



r 



CALLED TO TESTIFY ON 
BEHALF OF DEFENDANT 
REGARDING THE 
FRYE-DAUBERT ISSUES : 

DR. COLIN ROSS 

(Outside presence 

Examination - Mr. 

Examination - Mr. 

Examination - Mr. 

Examination - Mr. 

Examination - Mr. 

Examination - Mr. 



of jury) 

Waxman 

Barden 

Waxman 

Barden 

Waxman 

Barden 



CALLED TO TESTIFY ON 
BEHALF OF DEFENDANT: 



DR. 



COLIN ROSS 

(In presence of jury) 
Direct - Mr. Waxman 



16 
43 
60 
66 
77 
77 



86 



c 






13 



1 
2 
3 
4 

5 
6 



10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 



_ ■-— iis_ 

requested you to comment on what other scientists have 

proposed? 
A. Right. 

Q. Then there's a vast number of workshops that you have given? 
MR. BARDEN: Objection to "vast number," Your 

Honor . 
BY MR. WAXMAN: 



8 Q. Okay. Ninety-nine workshops, through Page 28, is that 



correct? 



Correct . 



Q. Whether 99 is vast or not -- 

THE COURT: Well, let me overrule the objection. 
The answer stands. Go ahead, Mr. Waxman. 
BY MR. WAXMAN: 



Q. 

A. 



Has that number increased in the last two years? 

There would probably be another 15 to 20. 

Okay. And without going through these individually, can you 

briefly tell the jury the types of workshops that you have 

presented the 115 or 120 or so? 

It's basically all kinds of workshops all over Canada and 

the United States, mostly on multiple personality disorder, 

dissociative disorders, varying from one hour to two full 

days; two full days of just me, I mean. 

Doctor, is there anything else about your background and 

experience that is contained in your Curriculum Vitae you 



13 



14 



,- -J 



^___ _ _116 

1 wish to discuss at this particular time? 

2 A. Not particularly. 

3 MR. WAXMAN: We're going to move on. I don't know 

4 if you want to break here or whatever. 

5 THE COURT: We started so late, let's take another 
B five minutes and we'll recess at four-thirty. 

7 MR. WAXMAN: Fine. 

8 BY MR. WAXMAN: 

9 Q. Doctor, I don't mean to ask you a five -minute question, but 

10 what is multiple personality disorder, or dissociative 

11 identity disorder? 

12 A. That's actually a two-day question. Basically the official 

13 definition of it is what I outlined earlier. You have thes^ 

14 different personality states or identity states that are 

15 much more separated off and experience themselves as being 

16 literally separate people. They take turns being in control 

17 f the body. There's some sort of amnesia there, it can be 

18 amnesia for things a long time ago or it can be current 

19 amnesia. When one of these personality states is in 

20 control, then the other one that was in control before comes 
2i back, the one that comes back may not remember what was 

22 going on while the other one was in control. It can't be 

23 caused just by alcohol blackouts or imaginary companions and 

24 so on. That's the basic official definition of it. 

25 Q 



I 



You indicated previously that it is a diagnostic entity 



CAUSE NO. DV98-3843 

MARTHA ANN TYO, § IN THE DISTRICT COURT 

§ 
Plaintiff, § 

STEPHEN ASH, PH.D., § 

MARY E. GRUNDMAN, L.P.C., § 

CHARTER BEHAVIORAL HEALTH § DALLAS COUNTY, TEXAS 

SYSTEM OF DALLAS, INC., BHC § 

MILLWOOD HOSPITAL, INC., D/B/A § 

CPC MILLWOOD HOSPITAL, § 

KATHLEEN STANLEY, MD., § 

COLIN A. ROSS, M.D., AND § 

JEROME STATMAN, M.D. § 

Defendants. § 14th JUDICIAL DISTRICT 

PLAINTIFF'S SECOND AMENDED PETITION 

COMES NOW Plaintiff, Martha Ann Tyo (f/k/a Martha Poe Hurt), 
complaining of Defendants, Kathleen Stanley, M.D., BHC Millwood Hospital, 
Inc., d/b/a CPC Millwood Hospital, Stephen Ash, Ph.D., Charter 
Behavioral Health System of Dallas, Inc., Colin A. Ross, M.D., Mary E. 
Grundman, L.P.C., and Jerome Statman, M.D. ("Defendants"), and 
respectfully shows the Court as follows: 

Parties 

1. Plaintiff, Martha Ann Tyo (f/k/a Martha Poe Hurt) ("Ms. Tyo"), 

is an individual residing in Van Zandt County, Texas. 

2. Defendant, Stephen Ash, Ph.D. ("Ash"), is an individual residing 
in Archdale, North Carolina, who has already appeared herein. 

3. Defendant, Mary E. Grundman, L.P.C. ("Grundman"), is an 

PLAINTIFF'S SECOND AMENDED PETITION Page 1 



individual residing in Scroggins, Texas, who has already appeared herein. 

4. Defendant, Charter Behavioral Health System of Dallas, Inc. 
("Charter"), is a Texas corporation doing business in the State of Texas, which 
has already been served with citation. 

5. Defendant, BHC Millwood Hospital, Inc., d/b/a CPC MiUwood 
Hospital ("Millwood"), is a Tennessee corporation doing business in the state of 
Texas, which has already been served with citation. 

6. Defendant, Kathleen Stanley, M. D. ("Stanley"), is an individual 
residing in Fort Worth, Texas, who may be served with citation at her home 
office, 508 South Adams, Fort Worth, Texas 76109. A motion for substituted 
service upon this Defendant is currently pending with this Court. 

7. Defendant, Colin A. Ross, M.D. ("Ross"), is an individual residing 
in Richardson, Texas, who may be served with citation at his home office at 1701 
Gateway Boulevard, Richardson, Texas 75080. 

8. Defendant, Jerome Statman, M.D. ("Statman"), is an individual 
residing in Fort Worth, Texas, who may be served with citation at John Peter 
Smith Hospital, at 1500 S. Main, Fort Worth, Texas 76104. 

Jurisdiction and Venue 

9. The amount in controversy in this case is within the jurisdictional 
limits of this Court. Venue of this lawsuit in Dallas County, Texas, is proper 
pursuant to Texas Civil Practices and Remedies Code § 15.002(1), because all or a 
substantial part of the events or omissions giving rise to the claim occurred in 

PLAINTIFF'S SECOND AMENDED PETITION Page 2 



Dallas County. 

Acts of Agents 

10. Whenever in this Petition it is alleged that Defendants did any act, 
it is meant that the Defendants performed or participated in the act or that 
Defendants* agents, officers, or employees performed or participated in the act 
on behalf of and under the authority of the Defendants. 

11. The actions of Stanley, as set forth below, the allegations against 
whom are incorporated herein by reference, were performed in her individual 
capacity and as either agent for or employee of Millwood. Therefore, Millwood is 
jointly and severally liable for the damages caused by Stanley's improper acts 
committed as part of Ms. Tyo's treatment. 

12. The actions of Ash, Ross, Grundman, and Statman as set forth 
below, the allegations against whom are incorporated herein by reference, were 
performed in their individual capacity and as either agent for or employee of 
Charter. Therefore, Charter is jointly and severally liable for the damages 
caused by the improper acts committed as part of Ms. Tyo's treatment. 

Conditions Precedent 

13. All conditions precedent to Ms. Tyo's causes of action herein have 
been substantially complied with or Defendants have waived their rights to 
demand compliance with them or Defendants are estopped from asserting 
noncompliance with them. 



PLAINTIFF'S SECOND AMENDED PETITION Page 3 



General Allegations 

14. Ms. Tyo brings this professional negligence action against 
psychiatrists, psychologists, therapists, social workers, consultants and 
directors who provided mental health services to her beginning in 1990 and 
continuing through 1997. Ms. Tyo sought this treatment for her depression and 
marital problems. However, the Defendants never addressed these problems. 
Instead, using improper and inappropriate treatment techniques directed at the 
"recovery" of supposed "repressed memories," Defendants diagnosed Ms. Tyo as 
suffering from multiple personality disorder ("MPD") and as a survivor of 
"Satanic ritual abuse" ("SRA"), supposedly suffered by Ms. Tyo as a child. The 
"repressed memory" phenomena, unsupported by reliable scientific data, is 
based upon the theory that a "memory," usually of a traumatic experience 
during childhood, can be "repressed," to the extent that there is absolutely no 
recollection of the trauma until therapy, or some other traumatic event, allow 
the "repressed" memory to be "recovered." 

15. Due to their emphasis upon and reinforcement of her "recovered 
memories" by Defendants, Ms. Tyo came to believe that she had been sexually 
abused by her mother, father, and other family members, that her family was 
part of an extended, transgenerational Satanic cult that engaged in the torture, 
murder, and cannibalism of numerous adults and children, and that Ms. Tyo, 
through one or more of alternate personalties or "alters," had abused her own 
son. It was these alters, supposedly created by Ms. Tyo's mind as a result of the 

PLAINTIFF'S SECOND AMENDED PETITION Page 4 



childhood trauma, who allegedly "held" the knowledge of these abusive events. 

16. Although, at various times during her treatment, Ms. Tyo informed 
Defendants that she did not recall these events and did not believe that they 
occurred, Defendants informed her that her doubts meant that she was in denial 
as a result of the cult's "programming" and that her continued "resistance to 
treatment" would prevent her from improving. Ms. Tyo's therapists, alleged 
"experts" in "cult programming," supposedly discovered during the course of 
their treatment that Ms. Tyo had been "programmed" by the cult, and they led 
Ms. Tyo to believe that these horrific allegations were true, that she had been 
"programmed" by a cult and that Defendants could "deprogram" her. Ms. Tyo 
states that these events of "cult programming" did not, in fact, occur and the 
"memories" of these events were actually the product of the coercion and 
suggestion resulting from the improper techniques employed by Defendants 
herein. 

17. Defendants not only failed to inform Ms. Tyo that the treatment 
techniques provided to her are unsupported by any reliable scientific support, 
but they also failed to advise her that the diagnoses themselves are controversial 
and that the mental health community is divided about whether memories can 
be "repressed" and whether "multiple personalities" or organized Satanic cults 
exist. Thus, Ms. Tyo lacked the information necessary to allow her to make a 
reasoned and informed decision to consent to the treatment rendered to her by 
Defendants. 

PLAINTIFF'S SECOND AMENDED PETITION Page 5 



18. Rather than assisting Ms. Tyo with her mental and emotional 
problems, Defendants' treatment of Ms. Tyo caused her to become increasingly 
mentally and emotionally dysfunctional and to isolate herself from her family of 
origin and to cut off all contact with the outside world. As a result of this 
treatment, Ms. Tyo had all ties with her three children legally severed, 
underwent over six years of unnecessary and improper treatment, incurred 
significant medical expenses, suffered the end of her marriage, attempted 
suicide on at least three occasions, engaged in self-mutilation and endured 
unbelievable physical pain and suffering and mental anguish. 

Facts of the Case 

19. in 1990, Ms. Tyo was a thirty-two year old mother of three adopted 
children married to Bobby Gene Hurt ("Mr. Hurt"). Sometime during 1990, Ms. 
Tyo and Mr. Hurt, began marriage counseling. The marriage counselor referred 
Ms. Tyo to a psychiatrist, Kathleen Stanley, M.D. ("Stanley"), to seek counseling 
for Ms. Tyo's personal issues, as well as to obtain medical treatment for 
depression. Within the first few sessions, without performing any psychiatric or 
psychological tests or analysis, and with no basis whatsoever for asking the 
question, Stanley asked Ms. Tyo if she remembered anyone in her family 
touching her inappropriately as a child. Ms. Tyo told Stanley she had no such 
memories, but Stanley insisted that the reason Ms. Tyo could not remember the 
entirety of her childhood was because she had "repressed memories" of incest. 
Stanley also conferred with Ms. Tyo's husband, Mr. Hurt, and he, too, was 

PLAINTIFF'S SECOND AMENDED PETITION Page 6 



persuaded by Stanley that Ms. Tyo had suffered childhood sexual abuse at the 
hands of her family, to the detriment of their marriage. Throughout the course 
of her treatment, rather than providing the care and treatment expected of a 
physician specializing in psychiatry, Stanley failed to properly diagnose and 
treat Ms. Tyo's depression, instead misdiagnosing her as an incest survivor with 
"repressed memories" without any significant evidence supporting her medical 
conclusion. 

20. Using suggestive and hypnotic techniques, Stanley counseled Ms. 
Tyo to regress to a childlike state, to let the "inner child" speak and recall the 
alleged incidents of abuse. During many of these sessions, Stanley would give 
Ms. Tyo a stuffed animal and instruct Ms. Tyo to sit on a rocking sofa so that 
Stanley held her, almost like a child. In this environment, Stanley pressed Ms. 
Tyo to relate any and all bodily sensations which Stanley would diagnose and 
describe as "body memories" of abuse. Stanley also encouraged Ms. Tyo to read 
"The Courage to Heal" and to use the accompanying workbook to help draw 
forth "memories" of abuse. Stanley instructed Ms. Tyo to write with her 
opposite hand to let her "inner child" speak. Stanley never consulted with Ms. 
Tyo about the type of therapy she was using, its risks and dangers, or the fact 
that the concept of "repressed memories" was the subject of controversy within 
the therapeutic community. 

21. Stanley acted as Ms. Tyo's therapist from 1990 through 
approximately March of 1991. Prior to beginning therapy with Stanley, Ms. Tyo 

PLAINTIFF'S SECOND AMENDED PETITION Page 7 



had definite memories of abuse inflicted by a former musical instructor and her 
brother-in-law, but no memories of any abuse inflicted by any family members. 
However, as a result of the improper hypnotic, suggestive and coercive 
techniques used by Stanley, Ms. Tyo "remembered" sexual and physical abuse 
allegedly inflicted by both her parents, two of her brothers and several of her 
neighbors. These "memories" included alleged vaginal and anal intercourse 
with her father as early as age two years old and inappropriate fondling by her 
mother while she was still in diapers. 

22. As she struggled to "remember" the supposed abuse, Ms. Tyo 
became increasingly dependent upon Stanley. She was completely focused on 
trying to get better by "remembering" her supposedly abusive childhood and 
Stanley would praise her and compliment her when she did "remember." 
However, Ms. Tyo continually questioned the veracity of such "memories." Ms. 
Tyo told Stanley that she had a happy childhood. She told Stanley her very large 
family lived in a small house and she never had her own room as a child. She 
questioned how her "memories" of abuse could have gone unnoticed in this 
environment. Without any independent verification, Stanley continually 
affirmed to Ms. Tyo's that her "memories" were true and that she would have to 
uncover all her "memories" of abuse and relive such "memories" before her 
condition would improve. 

23. During her treatment with Stanley, Ms. Tyo's ability to rationally 
function became increasingly diminished, and Ms. Tyo herself came to believe, 

PLAINTIFF'S SECOND AMENDED PETITION Page 8 



through the emphasis upon and reinforcement of her "recovered memories," 
that she had suffered repeated sexual and other traumatic abuse as a child by 
her family. In fact, these events did not occur, and these beliefs were the product 
of the coercion and suggestion resulting from the improper techniques employed 
by Stanley. These techniques were utilized without advising her that the 
hypnotic and other supposed therapeutic techniques utilized in her treatment 
were capable of causing false beliefs and memories of events which never 
occurred. Further, Stanley never attempted to independently verify Ms. Tyo's 
"memories," and she never obtained any consultation regarding her diagnosis, 
despite the fact that Ms. Tyo's condition only worsened significantly under 
Stanley's care. 

24. In January of 1991, Stanley hospitalized Ms. Tyo at CPC Millwood 
Hospital ("Millwood") in Arlington (now known as BHC Hospital) allegedly to 
provide Ms. Tyo the "benefit" of exposure to other alleged incest survivors. 
While at Millwood, Ms. Tyo attended group therapy sessions with alleged incest 
survivors. During these group sessions, Ms. Tyo would listen to the "memories" 
of other "survivors" and would relate what she allegedly "remembered." When 
she questioned the "memories," the group leaders, employees of Millwood, told 
Ms. Tyo she was in denial, which was to be expected in her situation. She also 
continued her weekly sessions with Stanley, continuing the regression therapy 
described above. 

25. In addition, during this hospitalization, Stanley urged Ms. Tyo to 

PLAINTIFF'S SECOND AMENDED PETITION Page 9 



confront her family about her "memories" of abuse. Stanley instructed Ms. Tyo 
to inform her family that she would cease all contact with them unless they 
admitted to the abuse and entered counseling for same. Although her parents 
were unable to attend this "confrontation," several of Ms. Tyo's siblings 
attended. After they denied Ms. Tyo's accusations, Ms. Tyo severed all contact 
with her family. Prior to confrontation, Stanley had told Ms. Tyo to expect their 
denials, and that the denials were actually confirmation that the abuse did 
occur. Ms. Tyo remained at Millwood for approximately two to three months. 

26. Subsequent to her hospitalization, Ms. Tyo continued therapy with 
Stanley and continued attending group sessions. After she attended one group 
therapy session where another woman discussed her "memories" of snakes in 
cult ceremonies, Ms. Tyo recalled a "memory" involving snakes. Stanley 
interpreted Ms. Tyo's "memory" as an indication that Ms. Tyo's had been or was 
currently involved in a Satanic cult, and she referred Ms. Tyo to a "cult 
specialist," Ash, for testing. 

27. Ash recklessly and uncritically accepted Stanley's diagnosis that 
Ms. Tyo was a victim of both childhood sexual abuse by her family and Satanic 
ritual abuse with "repressed memories" of same, and he failed to perform 
available and competent tests which might have disclosed the true nature of Ms. 
Tyo's mental condition. Ash analyzed Ms. Tyo using only a Rorschach test. 
Upon completion of the examination, he informed Ms. Tyo that he had "good 
news and bad news." The "good news" was that she was extremely intelligent. 

PLAINTIFF'S SECOND AMENDED PETITION Page 10 



The "bad news" was that she had multiple personality disorder, which would 
require at least seven to ten years of therapy. The theory of MPD, which is 
neither supported by clear, scientific evidence nor widely accepted by the 
mental health community, may be described as the existence within the person 
of two or more distinct personalities or personality states or "alters" (each with 
its own pattern of perceiving, relating to or thinking about the environment and 
self), which recurrently take full control of the person's behavior. Supposedly 
the trauma of being a Satanic Ritual Abuse ("SRA") victim results in the 
individual suffering from MPD. 

28. Prior to this time, Ms. Tyo had never been diagnosed as having any 
type of disassociative disorder whatsoever. Stanley informed Ms. Tyo that 
multiple personality disorder ("MPD") and Satanic ritual abuse ("SRA") were 
beyond her professional capabilities, and she advised Ms. Tyo to continue 
therapy with Ash. At this time, Ms. Tyo ceased counseling with Stanley, 
although Stanley continued to prescribe anti-depressants for Ms. Tyo in 
coordination with Ash's therapy. 

29. During her therapy with Ash, Ms. Tyo attended private weekly 
therapy sessions wherein Ash attempted to "call forth" and identify all of Ms. 
Tyo's alternate personalities ("alters"). Ash employed inappropriate hypnotic, 
suggestive and coercive techniques to discover the existence of these alters. In 
fact, these alters did not exist, and Ms. Tyo's belief in their existence was the 
product of the coercion and suggestion resulting from the improper techniques 

PLAINTIFF'S SECOND AMENDED PETITION Page 1 1 



employed by Ash. These techniques were utilized without advising her that the 
hypnotic and other supposed therapeutic techniques utilized in her treatment 
were capable of causing false beliefs and memories of events which never 
occurred. Further, Ash never attempted to independently verify the veracity of 
Ms. Tyo's "repressed memories," and he never obtained any consultation 
regarding his diagnosis, despite the fact that Ms. Tyo's condition only worsened 
significantly under Ash's care. 

30. Prior to her hospitalization again in 1992, Ash diagnosed at least 
sixteen different alters, some of whom were allegedly "demons" created by Ms. 
Tyo's alleged participation in Satanic cult activities as a child. In addition, Ms. 
Tyo recalled "memories" indicating that the entirety of her family and the 
majority of her neighbors were involved in Satanic ritual activities including 
murder and cannibalism. Ash never consulted with Ms. Tyo about the type of 
therapy he was using, its risks and dangers, or the fact that MPD and SRA were 
the subject of controversy within the therapeutic community. 

31. Ash educated Ms. Tyo on the alleged "triggers" used by Satanic 
cults. According to Ash, any and all contact with her family would be filled with 
these "triggers" as her family attempted to draw her back into the cult. These 
"triggers" extended even as far as a greeting card displaying colored flowers. 
Ash informed Ms. Tyo that the colors and type of the flowers were all different 
"triggers" designed to lure Ms. Tyo into Satanic cult activity. 

32. In an effort to "free" Ms. Tyo from the cult and rid her of her 

PLAINTIFF'S SECOND AMENDED PETITION Page 12 



"demon personalities," Ash performed "exorcisms" by putting his hand upon 
Ms. Tyo's head and calling for the demons to leave her body. Ms. Tyo became 
increasingly afraid of Ash as he repeatedly attempted to exorcise the demons 
during therapy sessions. Furthermore, during the course of her treatment with 
Ash, Ms. Tyo became increasingly disturbed and suicidal as she came to believe, 
through the emphasis upon and reinforcement of her "recovered memories," 
that she had participated in ritual murders, cannibalism, Satan worship, and 
torture by members of her family and the Satanic cult. 

33. On February 12, 1992, Ash hospitalized Ms. Tyo, after a suicide 
attempt, at a hospital run by Charter Behavioral Health System of Dallas, Inc. 
,, <;/ ("Charter"). During this hospitalization, Ms. Tyo was also introduced to Colin 
^ A. Ross, M.D. ("Ross"), head of the MPD Unit at Charter and Ash's supervisor. 

In addition to Ash, Stanley and Ross, during this hospitalization, Ms. Tyo was 
treated by several different counselors, physicians and nurses at Charter, 
including Dr. Jerome Statman, M. D. ("Statman") and M.E. Grundman, L.P.C. 
("Grundman"), most or all of whom were employed by Charter. Ms. Tyo was 
placed in the MPD ward at Charter and was surrounded with over twenty 
women, all allegedly afflicted with MPD, who were performing acts of 
self-mutilation on a regular basis. While supposedly under hospital supervision, 
and under the influence of the other unfortunate women with whom she was 
hospitalized, Ms. Tyo was allowed to burn her breasts and ankle with cigarettes 
and to burn an inverted cross on one of her hands on or about February 16, 1992. 

PLAINTIFF'S SECOND AMENDED PETITION Page 13 



Ash, her treating therapist at Charter, "determined" that "Stephen," an alter 
who was a practicing Satanist and was controlled by demons, was the culprit 
responsible for Ms. Tyo's self-mutilation, 

34. Despite the fact that Charter was now aware that Ms. Tyo was prone 
to self-mutulation and despite the fact that Ms. Tyo was now supposed to be 
under one-on-one supervision, Ms. Tyo was allowed to carve "SATAN'S BODY" 
on herself and to cut an inverted cross across her entire upper torso on March 4, 
1992. Whenever Ms. Tyo "acted out" in this fashion, or appeared "out of control" 
in any way, she was forcibly carried by Charter employees into the "quiet room" 
where she was physically restrained against her will. While restrained, she was 
given injections in the hip to calm her down. 

35. Like "Stephen" described above, several of Ms. Tyo's alleged alters 
recalled "memories" of cult participation during her hospitalization at Charter. 
For example, an alleged alter, "Mawsa," recalled "memories" of a Satanic ritual 
where a man was nailed to an inverted cross, dismembered and burnt. 
Supposedly in the same ceremony, a young woman was also dismembered and 
Mawsa allegedly killed and ate the blood and the flesh of a sacrificed infant. 
Subsequently, she was allegedly married to and raped by the Devil. Again, Ms. 
Tyo constantly questioned the veracity of such "memories" or the existence of 
any alternate personalities. She was appalled and incredulous that she could 
even commit murder and participate in cannibalism. But she was repeatedly 
assured by Ash and her other treating counselors, physicians, and Charter 

PLAINTIFF'S SECOND AMENDED PETITION Page 14 



personnel, most or all of whom were Charter employees, that she did have 
multiple personalities and the "memories" of these alters were, in fact, true. As 
a result of the improper hypnotic, suggestive and coercive techniques used, Ms. 
Tyo came to believe these horrendous "memories." 

36. For example, while in Charter, Ms. Tyo "remembered" becoming 
pregnant and giving birth to multiple children fathered by Ms. Tyo's own father. 
She also "remembered" sacrificing these children to the cult and ingesting their 
blood and flesh. Ash, Ross and Statman told Ms. Tyo that these "memories" 
were true and were common experiences for individuals involved in SRA. 
Further, she "remembered" that she miscarried one of these children and that 
the child fell from Ms. Tyo's body into the toilet, at which time Ms. Tyo's mother 
allegedly flushed the fetus away. Ms. Tyo expressed incredulity that she could 
have forgotten having been pregnant and giving birth to multiple children, 
especially given the trauma she experienced after undergoing a hysterectomy at 
a young age and having to face the fact that she would never be able to have 
children. Nor could she comprehend how she could have killed any child she 
had birthed. Ms. Tyo knew she had stretch marks on her body, but her mother 
had always told her they resulted from the rapid weight gains and losses Ms. Tyo 
underwent while growing up. 

37. However, none of the treating doctors, counselors and staff at 
Charter, including Ash, Ross, Statman and Grundman, most or all of whom were 
Charter employees, challenged the veracity of these "memories." In fact, two of 

PLAINTIFF'S SECOND AMENDED PETITION Page 15 



the nurses at Charter, Miriam and Marcy, who were Charter employees, 
confirmed that the stretch marks resulted from pregnancy. A doctor at Charter, 
Dr. Cromer, went even further and told her that a lack of physical scarring did 
not mean that the "memories" did not occur. According to Dr. Cromer, the 
lining of her vagina, similar to the lining in the mouth, would not bear any 
evidence of sexual abuse, childbirth or mutilation of any kind. Once again, 
because of the techniques used upon her, Ms. Tyo came to believe these wild 
stories. 

37. Ms. Tyo's confusion and depression increased to such a point that 
she attempted to check herself out of Charter on or about March 5, 1992. 
However, she was falsely told by Charter employees that she would have to be 
committed to the state hospital if she checked herself out of Charter. Out of fear 
of being committed to the state hospital, Ms. Tyo rescinded the discharge papers 
and remained at Charter until May 15, 1992. 

38. At one point during her hospitalization, Ms. Tyo asked Ross for his 
help in determining whether or not she was MPD, and she expressed her 
concern regarding Ash's "exorcisms." By this time, Ms. Tyo was distraught and 
depressed as a result of the trauma inflicted by Ash's therapy. She was suicidal 
and her physical condition had also deteriorated greatly and she had not eaten 
solid foods for about two weeks. Ross confirmed the MPD diagnosis without 
conducting any appropriate tests and without any legitimate basis for doing so, 
and he assured her that he would speak with Ash about stopping the 

PLAINTIFF'S SECOND AMENDED PETITION Page 16 



"exorcisms." When Ash's behavior did not change, Ms. Tyo requested Ross 
become her treating therapist instead. At this time, late April of 1992, Ms. Tyo 
ceased all treatment with Ash and Stanley and began treatment with Ross and 
Grundman. 

40. From that point on, Ms. Tyo saw Ross and Grundman for counseling 
and psychotherapy concurrently. Ross and Grundman recklessly and 
uncritically accepted Ash's and Stanley's diagnosis and failed to perform 
available and competent tests which may have disclosed the true nature of Ms. 
Tyo's mental condition. Ross and Grundman both worked to attempt to identify 
even more alters, as well as "fragment" alters. Some of the alters were allegedly 
the operatives in the cult, such as Christian, Victor or Augusta - the high 
priestess. Others, such as Dean and Martha Ann, were allegedly the 
personalities that caused confusion and were the reason why Ms. Tyo never 
suspected she had MPD prior to this time. Both Ross and Grundman allegedly 
conferred with these alters, even with the alleged Satanists. In fact, these alters 
did not exist, and these beliefs were the product of the coercion and suggestion 
resulting from the improper techniques employed by Ross and Grundman. 
These techniques were utilized without advising Ms. Tyo that the hypnotic and 
other supposed therapeutic techniques utilized in her treatment were capable of 
causing false beliefs and memories of events which never occurred. Further, 
Ross and Grundman never obtained any consultation regarding her diagnosis, 
despite the fact that Ms. Tyo's condition only worsened under their care. 

PLAINTIFF'S SECOND AMENDED PETITION Page 17 



Neither Ross nor Grimdman consulted with Ms. Tyo about the type of therapy 
they were using, its risks and dangers, or the fact that MPD and SRA were the 
subject of controversy within the therapeutic community. 

41. On or about April 30, 1992, Ross told Ms. Tyo that she would have to 
leave Charter in three weeks, but Ross acknowledged that at that point she 
might still be suicidal and might still want to mutilate herself. Subsequent to 
that conversation, Ms. Tyo went through a period she describes as deep denial. 
She denied she was MPD or had participated in SRA. Ross and Grundman, 
however, forced her out of her denial by assuring her that their diagnosis was, 
in fact, correct and the "memories" she'd recovered were true. They videotaped 
her therapy sessions with Grundman to "prove" the existence of her alters and 
reminded her of the stretch marks "proving" her prior pregnancies. Once again, 
Ms. Tyo came to believe everything that she had "remembered." 

42. Ms. Tyo left Charter on or about May 15, 1992. Prior to leaving, she 
made arrangements to see Grundman every Monday and Wednesday and to see 
Ross every Friday. Ross and Grundman had agreed on a plan of therapy that 
included continuing to identify all of Ms. Tyo's alleged alters and to edit Ms. 
Tyo's happy childhood memories to remove all of the "illusions." Her therapy 
with Ross and Grundman continued in this fashion throughout the remainder of 
1992, but Ms. Tyo did not make any progress and her condition continued to 
steadily deteriorate. 

43. Ross and Grundman constantly reinforced the validity of Ms. Tyo's 

PLAINTIFF'S SECOND AMENDED PETITION Page 18 



"memories" of abuse at the hands of her family and the Satanic cult. Grundman 
insisted that Ms. Tyo was heavily programmed by the cult and that she could not 
have any contact with her family or the "programming" would take over and 
draw her back into cult activity. Furthermore, Ross and Grundman told Ms. Tyo 
that since she had already left the cult once, she would most likely be sacrificed 
if she returned. 

44. In June of 1992, Ms. Tyo visited her parents. At their next session, 
Grundman told Ms. Tyo that she had been reprogrammed and was in denial 
about the "programming." Throughout her therapy with Grundman, Grundman 
attributed Ms. Tyo's denial after any contact with her family as 
"reprogramming" and discouraged family contact. Grundman also encouraged 
Ms. Tyo to give away any and all gifts or objects given to her by her family or 
pictures of her family because such objects were "triggers" and Ms. Tyo needed 
to be rid of the "triggers" to be free of cult influence. Grundman even instructed 
her to get rid of clothes or objects of certain colors because they were "triggers." 

45. Like Ash, Grundman was considered a "Christian counselor." She 
identified several of Ms. Tyo's alleged alters as God, the Archangel Michael, and 
other angels who were working within the body to fight the forces of Satan. 
Grundman also held joint sessions with Ms. Tyo and Mr. Hurt, wherein she 
explained the workings of the different alters, and how to handle the appearance 
of the alters at home, to Mr. Hurt. 

46. Grundman and Ross continued identifying new and different alters. 

PLAINTIFF'S SECOND AMENDED PETITION Page 19 



Each alter was allegedly clothed with a particular "jobsuit" that dictated his/her 
role within the body. At one point in time, Ms. Tyo calculated that over 200 
alters or "fragment" alters had been identified with names such as Sherry, 
Loner, David, Geary, Christian, Dean, Martha, Joey, George, Lois, Katie, Mawsa, 
Augusta, Alice, Noah, Martha Ann, Little Martha, Karol, Victor, Bernadette, 
Catherine, Kate, Kathleen, Katrina, Katarina, Marty, and Martha M. Grundman 
counseled Ms. Tyo that the alters would each have to shed his/her "jobsuit" and 
become a part of the collective "system" to keep Ms. Tyo out of cult activity. In a 
"conversation" with one of the alters, Augusta - the Satanic High Priestess, 
Grundman absurdly tried to convince her to shed her "jobsuit" by pointing out 
the limited future for women in Satanic cults. 

47. Ms. Tyo was also encouraged by Grundman and Ross to read books 
about MPD and to write down and organize her alters. Grundman gave Ms. Tyo 
the books "A Mind of My Own," "Managing Our Selves; Building a Community 
of Caring" and "Managing Our Selves: God In Our Midst" and instructed her to 
read these books as guides for recovery. Ms. Tyo also went through lengthy 
exercises listing the name, birth date, age, purpose, and origin of each alter. She 
was also encouraged to write to each alter to ask for help in freeing herself from 
the cult. 

48. Grundman and Ross counseled Ms. Tyo on how to deal with her 
husband and children, as well. Grundman counseled Ms. Tyo to place the 
non-school age child, Jessica, in full-time daycare so that Ms. Tyo could work on 

PLAINTIFF'S SECOND AMENDED PETITION Page 20 



her therapy full-time. Grundman counseled Ms. Tyo to leave her husband and 
move out with the kids, which Ms. Tyo did in November of 1992, and she stayed 
separated from Mr. Hurt throughout the Thanksgiving holiday in 1992. 
Subsequently, Mr. Hurt was hospitalized for kidney problems and it was 
discovered he needed a kidney transplant, but still Grundman counseled Ms. 
Tyo to remain separated from her husband. 

49. In early December of 1992, Grundman held another joint session 
with Ms. Tyo and Mr. Hurt. In this session, Ms. Tyo and Mr. Hurt agreed to give 
their marriage another chance, but shortly thereafter their marriage was again 
strained as Ms. Tyo experienced extreme despair and depression and doubts 
about her marriage. Grundman attributed her condition to "anniversary 
programming" related to a Satanic cult holiday. During the 1992 hospitalization, 
Ms. Tyo had been given a schedule of all the Satanic or Occult "holidays." 
Throughout Ms. Tyo's therapy with Ross and Grundman, Grundman constantly 
referred to the schedule to relate any difficulties experienced by Ms. Tyo to a 
Satanic or Occult anniversary. Further, when Ms. Tyo experienced difficulties 
that did not correspond in time with a Satanic or Occult anniversary on the 
schedule, Grundman told Ms. Tyo her difficulties must relate to a holiday 
particular to her family's cult. 

50. In early January of 1993, Ms. Tyo experienced a severe crisis as Mr. 
Hurt required multiple surgeries due to his kidney condition. Ms. Tyo was 
unable to deal with the strain of her home life and her therapy. Ms. Tyo was 

PLAINTIFF'S SECOND AMENDED PETITION Page 21 



hospitalized in Charter again on January 29, 1993, after she attempted a drug 
overdose in front of her four year-old adopted daughter. 

51. Ms. Tyo's second experience at Charter was even worse than her 
first hospitalization. For the very first time, Grundman began to work with her 
on "integration," and Grundman urged her to shake off the cult "programming" 
that was separating her from her husband. Ms. Tyo's physical and mental 
condition spiraled downward. Charter counselors, employees of Charter, 
encouraged her more and more to let the child alters out to play. The incidents 
of self-mutulation increased, as did the incidents of forcible restraint in the 
"quiet room." Once she attempted to draw blood from her body using needles 
stolen by another patient. Another time, she banged her head against a concrete 
wall of the "quiet room" so loudly that it could be heard down the hallway. 
Fortunately, she was stopped before she could inflict serious harm on herself. 
She attempted suicide twice during this hospitalization, including attempting to 
hang herself in the "quiet room." Her parents visited her in the hospital, but 
Ms. Tyo's heavy state of medication made any communication impossible. Ms. 
Tyo remained in Charter until March 19, 1993. 

52. Ms. Tyo's relationship with Mr. Hurt fell apart completely in April 
of 1993. Mr. Hurt demanded she leave the house, leaving him with the kids and 
Ms. Tyo with no money or source of income whatsoever. Subsequently, Ross 
helped Ms. Tyo obtain government benefits on the grounds that she was totally 
disabled due to her MPD. In 1994, Mr. Hurt sued Ms. Tyo for divorce and, based 

PLAINTIFF'S SECOND AMENDED PETITION Page 22 



upon the advice of both Ross and Grundman, Ms. Tyo terminated her parental 
rights. Specifically, Ross and Grundman led her to believe she was a danger to 
her children who she dearly loved. In what she thought was their best interests, 
Ms. Tyo gave up her parental rights to her children. 

53. While hospitalized in Charter in 1993, Ms. Tyo began a relationship 
with a technician at Charter who worked for Charter under Ross on the MPD 
Unit, named Lawrence Samuel Tyo. Mr. Tyo continued seeing Ms. Tyo after Mr. 
Hurt demanded she leave the house. Subsequently, in October of 1993, Mr. Tyo 
moved in with Ms. Tyo. As their relationship grew, Grundman requested Mr. 
Tyo to attend Ms. Tyo's therapy sessions so that he could help Ms. Tyo work on 
her therapy at home. Grundman encouraged Mr. Tyo, who was totally 
untrained in psychoanalysis or counseling, to call out the alters at home and 
attempt to persuade them to remove their "jobsuits" and integrate with the 
system. 

54. Ms. Tyo's therapy continued with Ross and Grundman until the 
summer of 1995. Grundman and Ross continued to identify new alters and new 
"memories" of cult activity even as late as August of 1995. Ms. Tyo recalled 
"memories" of abuse by new perpetrators, especially her grandmother. 
According to these "memories," her grandmother belonged to a different cult 
that killed and ate animals instead of infants. She also "remembered" new 
incidents of abuse, including being forced to perform oral sex on her mother and 
grandmother. 

PLAINTIFF'S SECOND AMENDED PETITION Page 23 



55. Despite Ms. Tyo's desperate condition, Grundman terminated 
treatment with Ms. Tyo in the summer of 1995. Ms. Tyo asked both Grundman 
and Ross for a referral, but both said they thought she could work on her own 
with Mr. Tyo, the former technician at Charter. Ms. Tyo still had not 
reestablished contact with her family, although her family attempted to contact 
her several times after she ceased treatment with Grundman. Each time, Mr. 
Tyo called Grundman to ask whether it was advisable to allow Ms. Tyo contact 
with her family. Each time, Grundman told Mr. Tyo that Ms. Tyo should not 
risk contact with her family for fear of being drawn back into the cult. 

56. Subsequent to Grundman's termination of therapy, Ms. Tyo saw 
Ross for treatment on a regular basis to discuss her medication and her 
integration. Ms. Tyo repeatedly asked Ross to educate her on methods of 
discerning reality and how to live a normal life since she had been told her 
entire life up to that point had been dictated by the cult. Rather than providing 
Ms. Tyo with mechanisms for dealing with her current life, Ross encouraged her 
to continue working with Mr. Tyo on identifying and integrating alters. 

57. Ms. Tyo continued treatment with Ross including consulting 
regarding her progress in "integration" and receiving medication until April of 
1997, at which time Ross terminated his relationship with Ms. Tyo without 
referring her to any other counselors or physicians. Up through the time of 
termination, Ross never explicitly or implicitly questioned the veracity of Ms. 
Tyo's "memories" and, in fact, after Ms. Tyo's reestablished contact with her 

PLAINTIFF'S SECOND AMENDED PETITION Page 24 



family in the summer of 1996, Ross encouraged her not to confront her family 
regarding the "memories" but to let them maintain their denial. Until 1998, Ms. 
Tyo was incapable and unable to discover her causes of action against 
Defendants, as she firmly believed in the "memories" "uncovered" during her 
therapy with Defendants as a result of their overly suggestive hypnotic and 
coercive techniques. Ms. Tyo did not discover, and could not have discovered in 
the exercise of reasonable diligence, her causes of action against Defendants 
more than two years prior to filing suit against them because of the false 
memories and chaos they created in her. 

58. As a proximate result of her negligent treatment by Defendants, Ms. 
Tyo has lost everything. Since the early days of her therapy with Stanley, Ms. 
Tyo has gone from a fully functioning individual to a completely disabled 
individual totally dependent on therapy and her therapists. Prior to starting 
therapy with Stanley, Ms. Tyo had been evaluated and determined to be an 
acceptable parent for the three young children adopted by her and Bobby Gene 
Hurt. As a result of her therapy and subsequent hospitalizations, she was 
unable to work and unable to function either as a wife or as a mother to her 
family. As a result of her inability to function as a wife or a mother, Mr. Hurt 
sued Ms. Tyo for divorce. Subsequently, Ms. Tyo severed her parental rights to 
the children, leaving Ms. Tyo completely alone, as her relationship with her 
parents and siblings had been severed back in 1991. 

59. As a proximate result of Defendants' negligent conduct, Ms. Tyo has 

PLAINTIFF'S SECOND AMENDED PETITION Page 25 



suffered, and will continue to suffer in the future, severe mental distress and 
anguish and physical pain and suffering. In all likelihood, she will be physically 
and mentally scarred for life. Her entire past has been questioned and rewritten. 
Furthermore, as a result, Ms. Tyo's whole sense of identity has been destroyed. 
She continues to need psychological counseling as a result of this situation and 
will continue to need such counseling for the foreseeable future. In addition, as 
a result of Defendants' conduct, Ms. Tyo has suffered severe economic damages. 
As a result of the therapy she endured, Ms. Tyo is unable to work and depends 
on government assistance for her income. 

FRAUDULENT CONCEALMENT 
60. As described above, Defendants engaged in a continuous course of 
conduct to conceal their own wrongful actions. Defendants owed a duty to Ms. 
Tyo to disclose the risks and dangers of the therapeutic techniques they used, 
the controversial nature of the therapeutic techniques they used, and the fact 
that most of these techniques may cause false memories. Defendants failed to 
disclose this information and in fact confirmed the veracity of Ms. Tyo's 
"memories" when they knew such memories were or almost certainly had to be 
false. Further, to conceal their own wrongful actions, Defendants alienated Ms. 
Tyo from her family of origin and told her that any and all contact with her 
family might lead to her own harm and/or death. Therefore, Defendants 
separated Ms. Tyo from any and all individuals or information from which Ms. 
Tyo might have discovered the false nature of her memories. 

PLAINTIFF'S SECOND AMENDED PETITION Page 26 



61. This fraudulent concealment was done with the intent to deceive or 

defraud Ms. Tyo directly or was done with such recklessness or indifference as 

to amount to intent to defraud and deceive Ms. Tyo. The concealment by 

Defendants was fraudulent, oppressive and malicious and made with the intent 

to deceive Ms. Tyo. 

LIMITATIONS AND THE MEDICAL LIABILITY 
AND INSURANCE IMPROVEMENT ACT OF TEXAS 

62. Although the liability of some of the Defendants in this case may be 
governed by the Medical Liability and Insurance Improvement Act of Texas 
("MLIIA"), application of the two-year statute of limitations contained therein 
would be in violation of Article I § 13 of the Texas Constitution which states that 
the Legislature has no power to make a remedy by due course of law contingent 
on an impossible condition. That would include imposing a statute of 
limitations which cuts off a plaintiffs cause of action before the plaintiff has a 
reasonable opportunity to discovery the wrong and bring suit. In this case, Ms. 
Tyo, as described above, did not discover and did not have a reasonable 
opportunity to discover the wrong committed against her by the Defendants 
within two years of each Defendant ceasing to treat her. In fact, she did not 
discover her causes of action until 1998, at her very first opportunity. She gave 
the required statutory notice and filed suit promptly thereafter. Imposing the 
two-year statute of limitations provided in the MLIIA to causes of action against 
Defendants who ceased treatment of Ms. Tyo more than two years prior to the 

PLAINTIFF'S SECOND AMENDED PETITION Page 27 



filing of this suit would be unconstitutional. 

FIRST CAUSE OF ACTION-NEGLIGENCE 
(Against Stanley, Ash, Statman, Ross and Grundman) 

63. Ms. Tyo incorporates herein the allegations made in the proceeding 
paragraphs as if set forth here verbatim. 

64. Ash and Grundman each held themselves out to the community as 
competent mental health counselors and therapists. Stanley, Statman and Ross 
held themselves out in the community as competent psychiatrists and 
specialists in the treating of depression and psychological problems. Each of 
these Defendants violated the duty they owed to Ms. Tyo to exercise the ordinary 
care and diligence which reasonable and prudent counselors, psychologists, 
social workers and psychiatrists would have exercised under the same or 
similar circumstances. As set forth above, these Defendants breached this duty 
in multiple respects to Ms. Tyo, including, but not limited to: 

(a) failing to carefully evaluate Ms. Tyo's symptoms of which 
they knew or should have known and failing to seek and 
discover other symptoms; 

(b) failing to perform sufficient examinations of Ms. Tyo; 

(c) failing to perform sufficient diagnostic procedures on Ms. 
Tyo; 

(d) failing to make a proper diagnosis of Ms. Tyo's condition; 

(e) failing to investigate and determine Ms. Tyo's true condition 
prior to directing therapy and recommending medications; 

(f) failing to provide treatment for Ms. Tyo's depression, but 
rather creating other problems requiring continued and 

PLAINTIFF'S SECOND AMENDED PETITION Page 28 



extensive treatments; 

(g) improperly alienating Ms. Tyo from her family of origin; 

(h) improperly alienating Ms. Tyo from her husband and 
children; 

(i) failing to advise Ms. Tyo of the questionable nature of the 
therapeutic techniques being utilized in Tyo's treatment; 

(j) failing to advise Ms. Tyo of alternative treatments, 
considering the risks and benefits of the treatments utilized; 

(k) misrepresenting the merit of the therapeutic techniques 
being used in Tyo's treatment; 

(1) failing to advise Ms. Tyo that the diagnoses made regarding 
her condition were controversial and that the mental health 
community was divided as to their validity; 

(m) using improper, untested and unproven therapeutic 
techniques without the informed consent of Ms. Tyo; 

(n) taking and reinforcing as true and as representing real 
memories of actual historical events, without corroboration, 
the "memories" being uncovered under during the course of 
Ms. Tyo's treatment and advising Ms. Tyo as to the truth and 
reliability of these "memories"; 

(o) using hypnotic and other suggestive and coercive therapeutic 
techniques; 

(p) failing to obtain proper consultations or to properly refer Ms. 
Tyo to qualified and competent health care providers; 

(q) diagnosing Ms. Tyo with certain conditions without 
possessing sufficient training, expertise, and skill to make 
such diagnoses; 

(r) inducing or attempting to induce other mental health care 
providers to confirm or support the erroneous diagnoses and 
treatment of Tyo's supposed conditions, including MPD and 
SRA; 

PLAINTIFF'S SECOND AMENDED PETITION Page 29 



(s) undertaking treatment of Ms. Tyo for the conditions with 
which she was diagnosed while lacking sufficient skill, 
training, experience, critical judgment and/or objectivity to 
adequately treat such alleged disorders and causes; 

(t) failing to maintain adequate records of Ms. Tyo's diagnoses, 
examination, care and treatment; 

(u) inducing the creation and development of alters in Ms. Tyo 
and developing and reinforcing chaos in Ms. Tyo; 

(v) refusing to allow and/or discouraging Ms. Tyo from denying 
the diagnoses of MPD and SRA and the alleged activity of Ms. 
Tyo and her family in transgenerational Satanic cults, cult 
programming, cannibalism, assault, and murder; 

(w) failing to provide a boundary between Ms. Tyo's beliefs and 
their own professional evaluation of such beliefs; 

(x) providing only limited access to materials regarding MPD 
and SRA approved by them and not providing Ms. Tyo with 
books or articles taking counter positions; 

(y) as to Grundman and Ross only, abandoning Ms. Tyo's 
treatment without insuring that other competent 
professionals had taken over her care; 

(z) providing and allowing the provision of counseling and 
treatment by those without proper training and qualification; 

(aa) failing to adequately supervise staff and employees; 

(bb) confining, and subjecting Ms. Tyo to physical restraint, 
abreaction, confinement and physical, mental and emotional 
abuse without Ms. Tyo's informed consent; 

(cc) confining, and subjecting Ms. Tyo to physical restraint, 
abreaction, confinement and physical, mental and emotional 
abuse without Ms. Tyo's informed consent at a time when she 
was unable to give informed consent due to the deterioration 
in her medical, mental and emotional condition which was 
caused by these Defendants' negligent treatment of Ms. Tyo; 



PLAINTIFF'S SECOND AMENDED PETITION Page 30 



(dd) failing to stop, intervene and/ or take reasonable steps to stop 
the physical, mental and emotional abuse and exploitation of 
Ms. Tyo when these Defendants had the affirmative duty to do 
so; 

(ee) improperly using physical restraints in abreaction therapy; 

(ff) deceiving Ms. Tyo to remain in the hospital as a protection 
from a nonexistent cult and/or commitment to a state 
hospital; and 

(gg) creating a continuing serious dependency/hate relationship 
with Ms. Tyo, under which conditions therapy could not be 
effectively conducted. 

65. Each and every one of the foregoing acts and omissions, taken 

separately and collectively, constitutes negligence, and each and every one of the 

foregoing acts and omissions, taken separately and collectively, constitutes a 

direct and proximate cause of the damages to Ms. Tyo set forth below. 

SECOND CAUSE OF ACTION-NEGLIGENCE 
(Against Millwood and Charter) 

66. Ms. Tyo incorporates herein the allegations made in the proceeding 
paragraphs as if set forth here verbatim. 

67. Millwood and Charter held themselves out in the community to be 
competent hospitals, health care facilities and providers of psychiatric and 
therapeutic services. These Defendants violated the duty they owed to Ms. Tyo 
to exercise ordinary care and diligence which reasonable and prudent hospitals, 
health care facilities and providers of psychiatric and therapeutic services 
would have done in the same or similar circumstances and were, during the 

PLAINTIFF'S SECOND AMENDED PETITION Page 31 



course of their treatment of Ms. Tyo negligent in, at least, the following 
particulars: 

(a) Failing to provide competent treatment within their facilities; 

(b) Failing to determine the capability and competence of 
counselors, psychologists and psychiatrists providing 
treatment to their patients; 

(c) Failing to provide competent counselors, psychologists and 
psychiatrists to provide treatment to their patients; 

(d) Failing to use proper procedures and criteria prior to issuing 
credentials; 

(e) Failing to properly screen patients before submitting patients 
to psychiatric care; 

(f) Failing to supervise the psychiatric and psychological 
treatment of their patients; 

(g) Failing to perform adequate inspections of the conditions 
existing upon the unit which hospitalized Ms. Tyo; 

(h) Failing to' provide proper case and treatment for mental 
health problems; 

(i) failing to adequately supervise staff and employees; 

G) confining, and subjecting Ms. Tyo to physical restraint, 
abreaction, confinement and physical, mental and emotional 
abuse without Ms. Tyo's informed consent; 

(k) confining, and subjecting Ms. Tyo to physical restraint, 
abreaction, confinement and physical, mental and emotional 
abuse without Ms. Tyo's informed consent at a time when she 
was unable to give informed consent due to the deterioration 
in her medical, mental and emotional condition which was 
caused by these defendants' negligent treatment of Ms. Tyo; 

(1) failing to stop, intervene and/or take reasonable steps to stop 
the physical, mental and emotional abuse and exploitation of 

PLAINTIFF'S SECOND AMENDED PETITION Page 32 



Ms. Tyo when these defendants had the affirmative duty to do 
so; 

(m) improperly using physical restraints in abreaction therapy; 
and 

(n) deceiving Ms. Tyo to remain in the hospital as a protection 
from a nonexistent cult and/or commitment to a state 
hospital. 

68. Each and every one of the foregoing acts and omissions, taken 
separately and collectively constitute negligence in and of themselves and each, 
taken separately and collectively, constitute a direct and proximate cause of the 

harm to Ms. Tyo. 

THIRD CAUSE OF ACTION -NEGLIGENCE PER SE 
(Against Millwood and Charter) 

69. Plaintiff incorporates herein the allegations made in the preceding 

paragraphs. 

70. Plaintiff asserts that Defendants Millwood and Charter, each held 
themselves out in the community to be competent hospitals, health care 
facilities, or providers of psychiatric and therapeutic services. These 
Defendants violated the statutory duties which they owed to Ms. Tyo to exercise 
the ordinary care and diligence which reasonable and prudent hospitals, health 
care facilities, and providers of psychiatric and therapeutic services would have 
done in the same or similar circumstances and were, during the course of their 
treatment of Plaintiff, negligent perse in, at least, the following particulars: 

(a) Millwood and Charter, through their administrators, failed to 

PLAINTIFF'S SECOND AMENDED PETITION Pa S e 33 



provide the oversight of Ms. Tyo required by law, and thus violated 
Tex. Health & Safety Code Ann, § 576.022 (Vernon's 1992). 

(b) Millwood and Charter, through their administrators, failed to 
provide adequate psychiatric care to Ms. Tyo, and thus violated Tex. 
Health & Safety Code Ann. § 576.022 (Vernon's 1992). 

(c) Millwood and Charter, through their administrators, failed to 
provide adequate medical care to Ms. Tyo, and thus violated Tex. 
Health & Safety Code Ann. § 576.022 (Vernon's 1992), because during 
Ms. Tyo's treatment, Millwood and Charter failed to provide proper 
medical care to Ms. Tyo, although they knew or should have known 
of multiple medical problems, both caused by their treatment and 
independent of this treatment. 

(d) Charter violated Ms. Tyo's rights as a patient by mechanically 
restraining her unnecessarily, and thus violated Tex. Health & 
Safety Code Ann. § 576.021, 576.024 (Vernon's 1992). These 
mechanical restraints were knowingly administered in 
non-emergency situations, when there was no imminent probability 
of harm to Ms. Tyo or others, in violation of Texas law. 

(e) Charter provided excessive, unnecessary medication to Ms. Tyo in 
violation of Ms. Tyo's rights. Tex. Health & Safety Code Ann. § 
576.021(2) (Vernon's 1992). 

(f) Charter violated Ms. Tyo's rights by coercing her to revoke her 
requests for discharge. In these sessions, Ms. Tyo was threatened 
that she would be faced with involuntary commitment if she left 
Charter, and thus violated 25 TAC § 404.157. 

71. Because these statutes were written to protect patients such as Ms. 

Tyo, these breaches support findings of negligence per se. Each and every one of 

the foregoing breaches, taken separately and collectively, constitute a direct and 

proximate cause of the harm to Ms. Tyo. 

FOURTH CAUSE OF ACTION-GROSS NEGLIGENCE 
(Against All Defendants) 

72. Ms. Tyo incorporates herein the allegations made in the proceeding 

PLAINTIFF'S SECOND AMENDED PETITION Page 34 



paragraphs as if set forth here verbatim. 

73. Defendants' negligence was committed with malice, because their 
conduct, when viewed objectively from their standpoint at the time they engaged 
in it, involved an extreme degree of risk to Ms. Tyo and her family, considering 
the probability and magnitude of the potential harm to them, and because they 
had actual, subjective awareness of the risks involved, but they nevertheless 
proceeded with conscious indifference to the rights, safety and welfare of Ms. 
Tyo and her family. 

74. Accordingly, the imposition of exemplary damages against 

Defendants is justified, and Ms. Tyo seeks an award for same in an amount 

sufficient to punish Defendants and to deter them and others similarly situated 

from committing such gross negligence in the future. 

FIFTH CAUSE OF ACTION-FRAUD 
(Against All Defendants) 

75. Ms. Tyo incorporates herein the allegations made in the preceding 
paragraphs. 

76. Ms. Tyo further alleges that at all times material hereto, Defendants 
engaged in fraudulent conduct and/or fraudulent misrepresentations. As 
described above, from 1990 through 1997, Ms. Tyo was under the care of one or 
more of the Defendants at all times in order to extract from her and her medical 
insurance carrier the maximum amount of money that was available under the 
insurance policy and/ or so Defendants could use her as an experiment or project 

PLAINTIFF'S SECOND AMENDED PETITION Page 35 



("guinea pig") for their own personal agendas and/ or promotion as experts in 
the field. 

77. Defendants made material representations of fact to Ms. Tyo during 
the course of their treatment of her regarding her medical, psychiatric, and 
psychological conditions and the causes of these conditions. Ms. Tyo reasonably 
relied on these misrepresentations to her detriment. These misrepresentations, 
known by Defendants to be false and/or which were made by each of them 
recklessly, without any knowledge of their truth, and as positive assertions, 
were made repeatedly by Defendants during the course of their treatment of her. 
They include, but are not limited to, the following: 

(a) that she needed to be hospitalized and that she needed to be 
hospitalized for the amount of time she was hospitalized; 

(b) that she had repressed memories of childhood sexual abuse which 
she did not "remember" prior to beginning therapy with Stanley in 
1990; 

(c) that she suffered from multiple personality disorder (a/k/a 
disassociative identity disorder), repressed memory syndrome, and 
Satanic ritual abuse; 

(d) that she was the victim of Satanic ritual abuse; 

(e) that she had been and/ or was being programmed to engage in cult 
activities; 

(f) that she could only improve through the use of physical restraints, 
abreaction sessions, medications, hypnosis, confinement, and 
isolation; 

(g) that she was sexually abused from infancy through adulthood; 
(h) that she was suicidal and homicidal; 

PLAINTIFF'S SECOND AMENDED PETITION Page 36 



(i) that if she left the Defendants' care she would be committed to a 
state hospital and/or the cult would find her; 

(j) that Ms. Tyo needed extensive mental health treatment and 
hospitalizations for her condition, without which she would not "get 
well"; 

(k) that she had been a "perpetrator" of abuse in the cult; 

(1) that she had borne and killed multiple children; 

(m) that the individual forms of treatment provided would benefit her 
mental condition; 

(n) statements regarding the cost of and duration of her treatment; and 

(o) the experience held by each Defendants in the areas in which they 
provided treatment, advice, or consultation. 

78. Ms. Tyo reasonably relied on these representations; that is, she 
reasonably believed these representations of Defendants to be true, and she was 
thereby induced to consent to and/or submit to prolonged therapy and 
hospitalization, physical restraints, abreaction sessions, medications, hypnosis, 
confinement, and isolation. 

79. Ms. Tyo reasonably relied on these assertions of, or failures to 
disclose, material facts by Defendants by submitting to treatment and spending 
substantial amounts of money for therapy and treatment which she would have 
not done but for Defendants' assertions and omissions of material fact. As a 
proximate result of Ms. Tyo's reliance upon these representations and 
omissions, she has been damaged, monetarily, psychologically, mental, and 
physically, in a sum far in excess of the minimum jurisdictional limits of this 

PLAINTIFF'S SECOND AMENDED PETITION Page 37 



Court, and she seeks to recover the elements of damage set forth below. 

SIXTH CAUSE OF ACTION -CONSPIRACY TO COMMIT FRAUD 
(Against Stanley, Ash, Statman, Ross, Grundman and Charter) 

80. Ms. Tyo incorporates herein the allegations made in the proceeding 
paragraphs as if set forth here verbatim. 

81. During Ms. Tyo's hospitalization at Charter from February to May, 
1992, Stanley, Ash, Statman, Grundman, Ross, Charter, and other persons 
working for and/or connected with Charter were involved in a civil conspiracy 
to defraud Ms. Tyo. Specifically, Ross, Statman, Ash and Grundman had 
personal knowledge of the purpose of the conspiracy, and they intended to be 
involved in the conspiracy. 

82. During her hospitalization at Charter from January to March, 1993, 
Grundman, Ross, Statman, Charter and other persons employed by and/or 
associated with Charter were involved in a civil conspiracy to defraud Ms. Tyo. 
Specifically, Grundman and Ross had personal knowledge of the purpose of the 
conspiracy, and they intended to be involved in the conspiracy. 

83. During the course of their treatment of Ms. Tyo at Charter from 
February to May 1992, Stanley, Statman, Ash, Ross, Grundman and their 
co-conspirators consciously agreed and conspired to hospitalize Ms. Tyo and 
keep her hospitalized for the maximum possible period of time in order that they 
could extract the greatest possible amount of money from Ms. Tyo and her 
medical insurance company and so that they could promote their own 

PLAINTIFF'S SECOND AMENDED PETITION Page 38 



self-interests by using Ms. Tyo and her alleged illness and treatment to advance 
and promote their own standing, reputation, and esteem among their profession 
and business associates and the public generally. 

84. During the course of their treatment of Ms. Tyo at Charter from 
January to March 1993, Ross, Grundman and their co-conspirators consciously 
agreed and conspired to hospitalize Ms. Tyo and to keep her hospitalized for the 
maximum possible period of time in order that they could extract the greatest 
possible amount of money from Ms. Tyo and her medical insurance company 
and so that they could promote their own self-interests by using Ms. Tyo and her 
alleged illness and treatment to advance and promote their own standing, 
reputation, and esteem among their profession and business associates and the 
public generally. 

85. On both occasions, each of the co-conspirators consciously agreed 
among themselves: 

(a) to keep Ms. Tyo hospitalized by falsely representing to her and 
others that she suffered from multiple personality disorder (a/k/a 
disassociative identity disorder), repressed memory syndrome, and 
ritual abuse, and that she was involved in Satanic cult activity, 
ritual abuse, and transgenerational Satanic cult activity, among 
other activities; 

(b) to represent to Ms. Tyo and others that Ms. Tyo was homicidal and 
suicidal and a danger to herself, her children and others because of 
alleged past Satanic cult abuse, ritual abuse, child abuse, 
transgenerational Satanic cult activity, torture and homicide, 
among other activities; and 

(c) to refer Ms. Tyo to themselves and other treaters for further 
"treatment" to continue the conspiratorial scheme. 

PLAINTIFF'S SECOND AMENDED PETITION Page 39 



86. It was also part of the conspiracy that Stanley, Ash, Ross, 
Grundman and certain other co-conspirators, during their treatment of Ms. Tyo 
prior to and subsequent to her hospitalizations, would continue with the same 
practices in order to force her into further hospitalizations and to continue 
out-patient treatment in order to extract the greatest possible amount of money 
from Ms. Tyo and her medical insurance company and to promote their own 
self-interests by using Ms. Tyo and her alleged illness and treatment to advance 
and promote their own standing, reputation, and esteem among the profession 
and business associates and the public generally. 

87. Stanley's, Statman's, Ash's, Ross', Grundman's and their 
co-conspirators' acts and omissions in furtherance of the conspiracy, which 
were committed during the entire course of their treatment of Ms. Tyo, include, 
but are not limited to, the following acts and omissions of conduct: 

(a) misdiagnosing Ms. Tyo as suffering from multiple personality 
disorder (a/k/a disassociative identity disorder), repressed memory 
syndrome, and ritual abuse; 

(b) inducing or attempting to induce other health care practitioners or 
providers to confirm or support the erroneous diagnosis and 
treatment of multiple personality disorder, repressed memory 
syndrome, and ritual abuse; 

(c) engaging and/or allowing or encouraging other health care 
practitioners or providers to engage in activities under the guise of 
diagnosis and treatment which a reasonable professional would or 
should know were improper, harmful, or not within reasonable 
standards of care and/or which a reasonable professional would or 
should know were detrimental to Tyo's health, her family, social 
relationships, and emotional, mental, and physical health; 

PLAINTIFF'S SECOND AMENDED PETITION Page 40 



(d) subjecting Ms. Tyo to physical restraint, abreaction, confinement, 
and physical, mental, and emotional abuse without Tyo's informed 
consent; 

(e) subjecting Ms. Tyo to physical restraint, abreaction, confinement, 
and other treatment without her effective informed consent at a 
time when she was unable to give informed consent due to the 
deterioration of her medical, mental, and emotional condition 
caused by Stanley, Ash, Ross, Statman, Grundman and their 
co-conspirators' negligent diagnosis and treatment of Ms. Tyo; 

(f) inducing, encouraging, and/or forcing Ms. Tyo to believe events 
that never happened and/or for which Stanley, Ash, Ross, 
Grundman, Statman and the co-conspirators had no reasonable 
basis to believe happened, including, but not limited to, activity by 
Ms. Tyo and her family and others in transgenerational Satanic 
cults, cult programming, ritual abuse, physical and mental abuse, 
cannibalism, drug abuse, kidnapping, assault, and murder; 

(g) using techniques of therapy that encouraged guesses, speculation, 
and confabulation and/or in using pressure, instilling in Ms. Tyo 
fear of abandonment, drugs, hypnotherapy, indeomotor signaling, 
finger triggering, leading questions, and/or other suggestion to 
create, change, influence, infect, reinforce, and/or influence 
perception and beliefs; 

(h) using and/or recommending the use of psychoactive medications of 
improper type and/or dosage and/or in an improper fashion for 
purposes for which they were not intended and in treating 
psychiatric disorders for which they are of no proven value or are 
harmful and which impaired Tyo's mental function; 

(i) falsely diagnosing and continuing to diagnose Ms. Tyo as suicidal 
and homicidal without any facts or objective criteria to support this 
diagnosis and using this diagnosis as justification for continued 
therapy and commitment without any facts as objective criteria to 
support this diagnosis; 

(j) not investigating and/or verifying with appropriate psychological, 
psychiatric, medical, and physical exams alleged claims of physical 
and sexual abuse alleged inflicted on Ms. Tyo in Satanic rituals; 



PLAINTIFF'S SECOND AMENDED PETITION Page 41 



(k) iatrogenic inducement, reinforcement, and reinfection of probable 
induced delusional thoughts of Ms. Tyo which led to prolonged and 
unnecessary hospitalization; 

(1) inducing the creation and development of alters in Ms. Tyo and 
development and reinforcing chaos in Ms. Tyo; 

(m) never exploring or investigating the probability, hypothesis, or 
proposition that the alleged activity by Ms. Tyo and her family and 
others in transgenerational Satanic cults, cult programming, ritual 
abuse, physical and mental abuse, cannibalism, drug abuse, 
kidnapping, assault, and murder, and multiple personality disorder, 
repressed memory syndrome, and ritual abuse never existed, 
especially when no physical evidence existed to confirm the 
activities; 

(n) discouraging Ms. Tyo from denying the alleged diagnoses of 
multiple personality disorder, repressed memory syndrome, ritual 
abuse, activity by Ms. Tyo and her family and others in 
transgenerational Satanic cults, cult programming, ritual abuse, 
physical and mental abuse, cannibalism, drug abuse, kidnapping, 
assault, and murder; and punishing or threatening Ms. Tyo with 
withheld rewards, commitment, scare tactics, return to the alleged 
cult, and/or never seeing her family again if she denied the 
diagnoses, memories, or activities and/or did not cooperate with 
Stanley, Ash, Ross, Grundman, Statman and their co-conspirators 
in assisting Stanley, Ash, Ross, Grundman, Statman and their 
co-conspirators in supporting their false diagnoses and beliefs; 

(o) deceiving Ms. Tyo by convincing her to remain in the hospital as 
protection from a nonexistent cult; 

(p) exploiting the high hypnotizability, the window of psychological 
vulnerability, trance state, and/or emotional vulnerability of Ms. 
Tyo; 

(q) exploiting Tyo's susceptibility and transference wishes in the 
service of Stanley's, Ash's, Ross', Grundman's, Statman's and their 
co-conspirators' conscious and/or unconscious counter-transfer- 
ence; 

(r) placing Ms. Tyo in group therapy which reinforced and reinfected 
her thoughts and beliefs; 

PLAINTIFF'S SECOND AMENDED PETITION Page 42 



(s) suggesting and/or using hypnosis or hypnotic techniques in 
refreshing recollection when they knew that such therapy could 
cause distortion, induce false memories, and suspend critical 
judgment; 

(t) introducing individual exogenous material to Ms. Tyo for the 
purpose of artificially invoking false memory response, such as the 
use of movies and videotapes which Ms. Tyo was required to see, 
and in using videotapes, audio tapes, movies, and other material to 
educate Ms. Tyo about the cult ritual abuse, multiple personality 
disorder, repressed memory syndrome, ritual abuse, and to 
convince Ms. Tyo she was abused and that she abused others; 

(u) using methods of brainwashing and mind control on Ms. Tyo; and 

(v) creating and continuing a serious dependence/hate relationship 
with Ms. Tyo, under which conditions therapy could not be 
effectively conducted. 

88. The participation of Stanley, Ash, Ross, Grundman, Statman and 
Charter in this conspiracy proximately caused severe physical and mental 
injuries to Ms. Tyo, including the damages set forth below. 

89. The conspiratorial actions taken by Stanley, Ash, Ross, Grundman, 
Statman and Charter toward Ms. Tyo were part of a broader conspiracy and 
comprehensive pattern of fraud which existed to falsely diagnose and treat 
patients for non-existent mental illnesses and psychological problems, especially 
repressed memory of childhood abuse, Satanic ritual abuse, participation in 
Satanic cults, multiple personality disorder and other "disassociative 
disorders." This conspiracy allowed Stanley, Ash, Ross, Grundman, Statman 
and Charter to make millions of dollars through the hospitalization and 
out-patient treatment of such patients. 

PLAINTIFF'S SECOND AMENDED PETITION Page 43 



90. This conduct of Stanley, Ash, Ross, Grundman, Statman and 
Charter was committed with actual malice and/or intentionally and without just 
cause and/or willfully and wantonly, entitling Ms. Tyo to recovery of exemplary 
damages from them. Ms. Tyo seeks an award for exemplary damages in an 
amount sufficient to punish Stanley, Ash, Ross, Grundman, Statman and 
Charter and to deter them and others similarly situated from engaging in such 
conspiracy in the future. 

SEVENTH CAUSE OF ACTION-DTPA 

(Against Ash and Grundman) 

91. Ms. Tyo incorporates herein the allegations made in the proceeding 
paragraphs as if set forth here verbatim. 

92. Ms. Tyo is a consumer, as that term is defined by the Texas 
Deceptive Practices-Consumer Protection Act ("DTP A"), Section 17.41, et. seq., of 
the Texas Business and Commerce Code. 

93. Ash and Grundman have engaged in false, misleading, or deceptive 
acts or practices against Ms. Tyo as set forth in Section 17.46 of the DTPA, 
including, but not limited to, the following: 

(a) causing confusion or misunderstanding as to the approval or 
certification of their services; 

(b) causing confusion or misunderstanding as to their affiliation, 
connection, or association with, or certification by, each other, 
Ross, Charter and others; 

(c) representing that their services had sponsorship, approval, 
characteristics, uses or benefits which they did not have and that 
they had sponsorship, approval, status, affiliation or connection 

PLAINTIFF'S SECOND AMENDED PETITION Page 44 



which they did not have; 

(d) representing that their services were of a particular standard, 
quality or grade when they were of another; and 

(e) failing to disclose information concerning their services which was 
known at the time of their treatment of Ms. Tyo, which failure to 
disclose was intended to induce Ms. Tyo into accepting their 
services, which services Ms. Tyo would not have accepted had the 
information been disclosed. 

94. These false, misleading and deceptive acts of Ash and Grundman, 
all enumerated in Subsection (b) of Section 17.46 of the DTPA, were relied upon 
by Ms. Tyo to her detriment. Furthermore, these false, misleading and deceptive 
acts and practices constituted express misrepresentations of material fact that 
cannot be characterized as advice, judgment or opinion. They also include a 
failure to disclose information in violation of Section 17.46(b)(23) of the DTPA. 

95. Ash and Grundman engaged in unconscionable actions or an 
unconscionable course of action against Ms. Tyo, in that they engaged in acts or 
practices which, to Tyo's detriment, took advantage of Tyo's lack of knowledge, 
ability, experience and capacity to a grossly unfair degree. These 
unconscionable actions or course of action cannot be characterized as advice, 
judgment or opinion. 

96. Pursuant to DTPA § 17.50(b), Ms. Tyo is entitled to recover from Ash 
and Grundman all of her economic damages caused by Ash's and Grundman's 
DTPA violations, including, but not limited to, past counseling and medical 
expenses, future counseling and medical expenses, lost earnings in the past and 

PLAINTIFF'S SECOND AMENDED PETITION Page 45 



lost earnings in the future. The amount of these damages exceeds the minimum 
jurisdictional amount of this Court. 

97. All of Ash's and Grundman's conduct was committed "knowingly," 
as that term is defined in the DTPA. Specifically, Ash and Grundman engaged in 
such conduct with actual awareness, at the time of the acts and practices 
complained of, of the falsity, deception, and unfairness of the acts and practices. 

98. Accordingly, pursuant to DTPA § 17.50(b)(1), Ms. Tyo is entitled to 
recover damages in excess of the minimal jurisdictional amount of this Court for 
the past and future mental anguish and the past and future pain and suffering 
she suffered as a result of Ash's and Grundman's DTPA violations. In addition, 
the jury may award Ms. Tyo up to three times the amount of her economic 
damages as exemplary damages. 

99. All of Ash's and Grundman's conduct was committed 
"intentionally," as that term is defined in the DTPA. SpecificaUy, Ash and 
Grundman engaged in such conduct and practices with actual awareness of the 
falsity, deception and unfairness of their acts and practices and with the specific 
intent that Ms. Tyo act in detrimental reliance on the falsity and deception of 
their conduct and/or in detrimental ignorance of the unfairness of their 

conduct. 

100. Accordingly, pursuant to DTPA § 17.50(b)(1), Ms. Tyo is additionally 
entitled to recover up to three times the amount of both her mental anguish 
damages and her economic damages, as exemplary damages. Pursuant to DTPA 

PLAINTIFF'S SECOND AMENDED PETITION Page 46 



§ 17.50(d), Ms. Tyo is also entitled to recover her court costs and reasonable and 
necessary attorneys* fees incurred in pursuing her suit against Ash and 

Grundman. 

DAMAGES 

101. Ms. Tyo seeks damages in excess of the minimum jurisdictional 
limit of this Court to compensate her for the following injuries proximately 
caused to her by Defendants' negligence, gross negligence, fraud, conspiracy and 
Ash's and Grundman's DTPA violations: 

(a) past counseling/medical expenses; 

(b) future counseling/medical expenses; 

(c) loss of past earnings; 

(d) loss of future earnings; 

(e) past pain and suffering; 

(f) future pain and suffering; 

(g) past mental anguish; 
(h) future mental anguish; 

(i) past and future loss of relationship with her children; and 
(j) exemplary damages. 

JURY DEMAND 

102. Ms. Tyo demands the trial of such cause by a jury pursuant to Texas 
Rules of Civil Procedure 216 and 217. Ms. Tyo previously tendered the jury fee of 
$30.00. 

PLAINTIFF'S SECOND AMENDED PETITION Page 47 



WHEREFORE, Plaintiff, Martha Ann Tyo (f/k/a Martha Poe Hurt), 
respectfully request that Defendants, Stephen Ash, Ph.D., Mary E. 
Grundman, L.P.C., Kathleen Stanley, M.D., BHC Millwood Hospital, Inc., 
d/b/a CPC Millwood Hospital, Charter Behavioral Health System of 
Dallas, Inc., Colin A. Ross, M.D. and Jerome Statman, M.D., be cited to 
appear and answer herein; that upon final trial hereof, Ms. Tyo receive judgment 
against Defendants for the damages set forth above, plus pre-judgment and 
post-judgment interest at the highest rates allowed by law or in equity, all costs 
of Court, and such other and further relief, general or special, legal or equitable, 
to which she may show herself justly entitled. 

Respectfully submitted, 




Mark H. Iola 
State Bar No. 00792294 
Roger L. Mandel 
State Bar No. 12891750 
Michelle Heron Galindo 
State Bar No. 00789859 

Stanley, Mandel & Iola, L.L.P. 

3100 Monticello, Ste. 750 
Dallas, Texas 75205 
(214) 443-4300 (Telephone) 
(214) 443-0358 (Telecopier) 

ATTORNEYS FOR PLAINTIFF 



PLAINTIFF'S SECOND AMENDED PETITION Pa S e 48 



CERTIFICATE OF SERVICE 

The undersigned hereby certifies that true and correct copies of the 
foregoing Plaintiffs Second Amended Petition were served this 7th day of 



August, 1998, upon the following counsel via the method indicated: 



Edwin P. Quillin 

Schell, Beene, Vaughan & Quillin, L.L.P. 

Suite 3100 

2200 Ross Avenue 

Dallas, Texas 75201 

V. Rock Grundman 

Rock Grundman & Associates 

P.O. Box 1347 

Mt. Vernon, Texas 75457 



Bradley K. Douglas 

Wright & Greenhill, P.C. 
1800 Bank One Tower 
221 West Sixth Street 
Austin, Texas 78701 



Qvia certified mail, return receipt requested 
□via fax #214-754-0060 
□ via first-class, U.S. mail 
□via overnight delivery 
□via hand delivery 

□via certified mail, return receipt requested 
□via fax # 903-860-3703 
□via first-class, U.S. mail 
□via overnight delivery 
□via hand delivery 

□via certified mail, return receipt requested 
□via fax # 903-860-3703 
□via first-class, U.S. mail 
□via overnight delivery 
□via hand delivery 




PLAINTIFF'S SECOND AMENDED PETITION 



Page 49 



PRESS RELEASE July 30, 1 998 

A former University of Manitoba professor who also practiced medicine at the St. 
Boniface General Hospital from 1985 to 1991 will be facing Texas justice. Dr. Colin A. 
Ross is facing fraud, gross negligence, fraudulent concealment, and conspiracy to commit 
fraud charges. He also faces charges under the Deceptive Practices Consumer Protection 
Act in the State of Texas. A number of Ross's colleagues also face the same charges 

A Winnipeg man says he is assisting the Texas Law firm of STANLEY, MANDEL & 
IOLA bring Dr. Ross to justice. George Bergen said the law firm approached him for 
assistance in May of this year. On July 2, 1998 the Texas law firm filed charges on behalf 
of Martha Ann Tyo a former patient of Ross. 

In 1994, a Winnipeg women filed a lawsuit against Dr. Ross. Roma Elizabeth Hart had 
been Ross's patient from 1986 to 1991 . In 1986 Hart was a 27 year old single mom and 
part time student in the University of Manitoba's Faculty of Education. She sought 
assistance at the U of M's Student Psych. Services in dealing with stress. Ross's graduate 
student Lynne Ryan in psychology took Hart to see Dr. Ross and within fifteen minutes 
Ross shook Hart's hand welcoming her to his Multiple Personality Disorder (MPD) 
therapy at the St. Boniface General Hospital. Ross informed Hart that her stress was due 
to incest and having been part of a satanic cult during her childhood. Hart pleaded that 
she had no memories of incest or cults. She was then subjected to memory recovery 
techniques that included hypnosis, age regression, dream imaging, suggestive 
questioning, exorcisms, body memories and massive doses of psychiatric drugs. Ross 
convinced Hart that for her to get better she needed to recover her repressed memories. 
At one point she was prescribed one hundred times the maximum recommended dosage 
of Halcion. Hart began to believe the incest and that she had been part of a Satanic cult 
during her childhood. Ross traumatized Hart by having her believe that she had been 
abducted and impregnated by aliens. Soon after she became Ross's patient, Hart was 
frequently hospitalized and was unable to look after her young daughter, work or 
continue with her education. The five year ordeal was a nightmare, Hart says. It included 
numerous suicide attempts, she said. The 1994 case against Ross had suffered from one 
legal delay after another. 

Bergen said that he filed charges against Ross in ApriL 1997 soon after he discovered that 
his sister-in-law, a computer operator, had been a patient at Ross's therapy clinic on the 
University of Manitoba campus in 1986. This 39 year old Winnipeg women went to 
Ross's clinic after she experienced a mild depression. Bergen said his sister-in-law was 
kept heavily drugged and she began to believe that during her childhood, her entire 
family had been part of a satanic cult that worshiped the devil in a northern Manitoba 
church. Shortly after attending the clinic she was hospitalized for two weeks. Three 
months later she was found dead in her apartment. I have no doubt that Dr. Ross is 
responsible for her death, Bergen says. He said she committed suicide because she could 
no longer live with the horrific false memories that were implanted in Ross's Clinic at the 
University of Manitoba 

His case against Ross was thrown out by the courts in February of 1998 on procedural 
technicalities, Bergen said. After studying his charges against Ross for seven months in 
1997, the Manitoba Court sited legal technicalities in dismissing the case instead of 

Page 1 



dealing with the substance of the charges. Bergen said he didn't have the financial 
resources to file an appeal. 

The fifty page Court action brought against Ross and other therapists and social workers 
at the Charter and Millwood Hospitals in Texas by Martha Ann Tyo reads like a six year 
witchcraft horror story out of the dark ages and surpasses the 1692 Salem Witch trials in 
terms of its absurdity, Bergen says. 

In 1990, Martha Ann Tyo, age 32 sought treatment for depression and marital problems. 
She was assessed as having MPD and informed that she had repressed memories of incest 
and abuse by a satanic cult. In therapy, Martha Ann came to believe that she had been 
sexually abused by her mother, father, and other family members and that her family was 
part of an extended, transgenerational Satanic cult that engaged in torture, murder and 
cannibalism of numerous adults and children. Martha Ann came to believe that one of her 
'alter' personalities had abused her own son. 

At the beginning of her therapy Martha Ann pleaded with her therapists that she did not 
have any memories of incest or being involved in cult activity described by her therapists 
and social workers. The therapists and social workers then informed her that she was in 
deep 'denial' as a result of the cult's "programming" and that her continued "resistance to 
treatment" would prevent her from improving. 

Martha Arm was advised to break all ties with her family in order that the therapists could 
"deprogram" her. 

The Court document says that as a result of Martha Ann's treatment she "had all ties with 
her three children legally severed, underwent over six years of unnecessary and improper 
treatment, incurred significant medical expenses, suffered the end of her marriage, 
attempted suicide on at least three occasions, engaged in self-mutilation and endured 
unbelievable physical pain and suffering and mental anguish". 

Hart and Bergen say they have had their complaints to the Manitoba College of 
Physicians & Surgeons and the Texas State Board of Medical Examiners rejected. 
Both licensing bodies showed a determined interest in shielding Ross, Bergen says. 



George Bergen 204-261-4386 or 204-9826432 (Winnipeg) 

Roma Hart 204-275-5723 (Winnipeg) 

Mark H. Iola 214-443-4300 (Attorney with STANLEY, MANDEL & IOLA) 

Michelle Heron Galindo (same as Mark H. Iola) 

Colin Ross 214-918-9588 (Dallas) 

Dr. Kenneth Brown 204-774-4344 (The Manitoba College of Physicians & Surg.) 

Belinda J. Ockels 903-786-81 94 (The Texas State Board of Med. Examiners) 

Emoke Szathmary 204-474-9354 (Pres. University of Manitoba) 

Jack Litvack 204-237-2920 (Pres. St. Boniface General Hospital) 

Charter Hlth Centre 214-519-1101 (Dallas) 

Lynne Ryan 204-985-5060 (Winnipeg) 



Page 2 



Winnipeg Free Press, Monday, August 24,1998 A9 



Patient suing 




Ex-city doctor planted false memories: lawyer 



By Alexandra Paul 

Medical Reporter 



A 



FORMER Winnipeg psychiatrist is being 
sued in Texas for allegedly planting false 
memories about childhood satanic abuse in 
a patient.; ■ •-,;■ ' 

Dr. Colin Ross, now a psychiatrist in Dallas, 
has been accused of similar allegations in two: 
Winnipeg lawsuits— one of which was dismissed', 
by the courtsin 1997 and one that is still before 
-the courts ■■*;. ■ ' .■ ' V",; 

-. .In the most recent lawsuit, by Texas, patient 
Martha Ann'Tyo, Ross and his psychiatric methods 
■are blamed' for Tyo's loss of her livelihood, her 
divorce and loss of custody of her three : children.: 
■ "Dallas lawyer Mark Ma said Typ' went to Ross 
;with stress. in 1990. She was told she, had multi- 
. 'pie personality disorder and had repressed mem- 
ories'o'f incest and abuse by a satanic cult. 
'■'•In Winnipeg, Ross faced two lawsuits^ after 
clients were supposedly diagnosed as victims of. 
satanists. ■ ■'■■' 

One 'suit was filed by Winnipeg's George 
Bergen, 'a relative of a patient who committed 
suicide. It was dismissed by the courts in 1997. 

The second one, by former Winnipeg patient 
Roma Elizabeth Hart, is still before the courts. 

In Texas,.Tyo's lawyer said while under Ross's 
care, his.clieht'was advised by therapists to break 
all family-ties so she could be deprogrammed. 

A court order'subsequently severed her legal 
ties to her children, her husband divorced her 
and she ended up on a government disability pen- 
sion. Medical bills for her care ran over $1 mil- 
lion, Iola said. 

Tyo attempted suicide three times and muti- 
lated herself during her six years of treatment, 
he said. 

"She was carving 'Satan's Boy' in her chest 
' with a razor blade and burning herself with cig- 
arette butts," Iola said. 

The three cases revolve around the contro- 



versial theory that victims of childhood abuse 
sometimes repress or block out traumatic mem- 
ories and later recover' them. Equally contro- 
versial in medical circles is the companion 
concept of false memory syndrome, in which 
fake memories of past trauma are said to be 
deliberately implanted in the psyche. - 
Ross has a private practice in Dallas and could 
, not be reached for comment, nor could state med- 
' ical board officials. Licensing officials in Manito- 
. ba record no disciplinary action against him here. 
':■:; Hart learned about the Texas suit from Bergen, 
.'V- who" offered to supply material about the Win- 
nipeg cases to the.Dallas lawyer. 

"■' "My statement of claim will look almost lden- 

: .j"tical to Ms Tyo's except I was given more drugs," 

■: : Hart said, referring to Halcion, a drug linked to 

bizarre mood changes that is also part of Tyo's 

suit.' ■','.' ... ■■*:■;£*• ■*■ • ' ' ■■: 

Hart filed -her". action' in 1994 in Manitoba and 
' said she is awaiting'a ruling on an application to 
: extend the statute of limitations that would allow , 
her case to proceed. 

Hart, a patient of Ross's from 1986-91 — the 
year he moved to Texas — alleges Ross con- 
vinced her that her stress was the result of incest 
and abuse by a satanic cult during her childhood. 
She said he also told her she was suffering emo- 
.- tional trauma after being impregnated by aliens 
• ' and brainwashed by the CI A. ■ 

In her court application, Hart said she alleges 
the trauma destroyed her life and left her unable 
to care for her young daughter or to work or pur- 
sue a university education, 

George Bergen filed a suit alleging false mem- 
ory syndrome on behalf of his sister in-law who 
committed suicide in 1986 while she was under 
Ross's care. The suit was dismissed in February, 
. George Bergen's ex-wife Bonnie Bergen filed 
a widely publicized suit alleging false memory 
syndrome which she claimed was the fault of 
another Winnipeg counsellor, not Ross. In 1996, 
it, too, was dismissed. 



Testimony of Thomas Brown 
Taken May 15, 1996 

On June 5, 1994, I received a phone call from my wife, Kathleen Anne Brown who was at the 
Charter Hospital inpatient facility in Dallas Texas directed by a Dr. Colin Ross. She was being 
treated for, in her words "integration of personalities" brought on by MPD or Multiple Personality 
Disorder. ' My wife claims that, remembered though therapy, she is the victim of satanic ritualized 
abuse involving major portions of her childhood years and that this is the cause of her emotional 
problems. Other professional opinions indicate major depression, which occurs in patients 
regardless of past history. This was her first visit to the facility and she had been there roughly a 
week or two. 

She began "I know so much more now!". She then described how she was learning from "new 
things being researched by Dr. Ross" about mind control "abuse programs" conducted by the CIA. 

My response was that the mind control experiments done by the CIA were already well publicized 
and not new (revealed around the mid 1970's). I also explained to her that if she was part of a 
cover up scheme that I would have run into problems somehow long ago when I worked on 
technically sensitive projects at a defense contractor. She emphasized that "this is all new stuff, 
he's (presumably Dr. Ross) only known about this for about 18 months" and stated that it 
involved a "very organized conspiracy with child sex abuse rings". This 18 months would 
correspond with the advent of Dr. Ross's unpublished report on the subject as compiled from 
information he gathered as a result of the freedom of information act for classified documents. 
She stated that "He (presumably Dr. Ross) says how it happened". From this I infer that he spoke 
directly with patients about the issue. She stated that Dr. Ross had spoken to them within the 
previous few days of this phone call. 

Kathleen then asserted that she also was a victim of this abuse and made new accusations against 
her parents. No accusations were made against me. 

From that time, Kathleen has had several visits to the facility and in February of 1995, moved to a 
location closeby for better support. Her mental health has eroded badly since that first visit. 

To me it appears that there was an intentional seeding of information to knowingly vulnerable 
patisrftayvjkuhe expectation of iatrogenically introducing new symptoms. 




Thomas Brown 



Thomiis Brown 

1216 Laurel Avonue 

St. Paul, MN 55104 

(612)647-9012 (w) 687-5436 



August 22, 1995 



George Bergen 

1 50 Dorge Drive 

Winnepeg, Manitoba CANADA R3VIM4 




Mr. Bergen 



o v 



I obtained your name from Matt Keenan who is preparing a story about FMS and the involvement of 
Dr. Colin Ross in particular. 

My (former) wife, was and still is being "treated" by Dr. Ross. Her treatment by Dr. Ross and others 
who advocate his treatment model has fractured our family. We now unfortunately are divorced after 
a unfortunate sequence of events that put our two young children though some physical and, I'm sure, 
emotional trauma. 

It sounds like our stories have a number of similarities. 

For your benefit, here are a few highlights: 

She was diagnosed by a Dr. David Hielner (Yarmouth Maine) , after only one 45 minute session, that 
she has a condition called Multiple Personality Disorder or Multiple Identity Disorder (as classified by 
DSM IV). As far as I can tell, no medical records about past treatment of depression was present when 
the diagnosis was made. Dr. Hielner is a strong advocate of Dr. Colin Ross and repressed memory 
therapy. A few weeks before the diagnosis, Dr. Hielner had been to a seminar sponsored by Ross 
which described the repressed memory/MPD model. My wife borrowed Ross's book regarding MPD. 
She spent hours staying up late at night saying "I have this!" or "this is me!" every few minutes. This 
of course heavily reinforced the diagnosis to her. 

On June 3, 1 994, during the first visit to Charter Hospital, my wife called up hysterical because she 
"now realized" that she was part of government sponsored "programming". The lead up to this 
determination was described as follows: Dr. Ross had a group session where he described the CIA 
mind control theory. It was stated that it was "new stuff just getting un-repressed by victims". I 
thought (and later found out to be correct) that this was data from the 25 year declassification rule. 
Later that same day, patients were subjected to a "guided imagery" session where they are allowed to 
use their imagination to create "memories". Within 24 hours, my wife and at least 2 other patients (her 
closest friends in the therapy group) were convinced that they were victims of the CIA plot. After 
this, my wife was deeply suspicious of everyone for a time from the water meter checker to the 
postman. She was told that there would be a special word that would "trigger" a response and cause 



her to commit a crime or suicide. Dr. Ross testified at the Humanansky trial regarding his CIA plot 
theories. The main project he referred to was "project artichoke". This project terminated in 1953 
according to Ross. My wife was not born until 1957. 



As early as 1990 however, my wife claims that she was part of a satanic ritual abuse cult (long before 
her visit to Charter Hospital) The most notable portion of it was that she was reinforced by her 
therapist at the time that she had given birth to babies as early as age 10 and was then forced to 
dismember them and drink their blood. Earlier, before al! of this started, she stated that her periods 
didn't begin until age 13. 

Over the few years that we have endured this, we (meaning myself and my two children) have seen a 
loving mother turn into an isolative and depressed basket case that willingly abandoned her children 
and spend their college savings bonds to support her therapeutic "habit" . At the time of our divorce, I 
gave her a choice, either to stay with the children and me or to go with her friends at Charter. She 
soon disappeared with little notice to Charter Hospital. 

In my opinion, having lived with this for a number of years, this is another way that, again, women 
have been victimized. The real losers in this are the patients (overwhelmingly women) who destroy 
their most important relationships and in the end only get anger, frustration, depression and loneliness. 
Perhaps the saddest and most telling relationship that it effects is their relationship with their 
children... it ruins it. 

I am doing my utmost to expose Dr. Ross and his theories. Because my former wife is not (yet) a 
retractor, there will probably not be any legal action against Ross at this time. I however intend to be 
very vocal about evidence which exposes his disasterous treatment methods. 

If there is any information that I could provide to assist you, please ask. 




M 



Thursday, September 2U, 1990 

Pnqa 2 

. _ . ... , ^ . „ Richard Fast. Provincui Tililor 





es pro 
animal mutilations 



.came, 



By Paul Wiecek 

The Manitoba RCMP are investigating 
incidents of criminal activity Involving 
Sntanists — including the mutilation of ani- 
mals — which have been occurring 
throughout the province recently. 

"We've been seeing things that can only 
be described as strange. Bizarre graffiti, 
mutilated animals, carcasses turning up in; 
various places — it runs the whole 1 gamut,".' 
RCMP spokesman Cpl. Wymart iSangster 
said yesterday. 

Sangster made the statement the same 
day the Free Press quoted from a- report 
that identified eight Manitoba to\yns with 



connections to Satanic cuits based In Win- 
nipeg. *" ! j •' ' ''" "'' ■ t'''- f\; 

ffie report, wrntenTiy Winnipeg Const.: 
Russ Heslop; cited a reliable informant In \ 
naming Flirt Flon, The Pas, Thompson; ; 
Winkler, Brandon, Grand Marais and the!; 
J.ickhead Indian reserve as places in Man- 
itoba with Satanic cult connections. 



QXsAj 



^LJUf^ 




Sangster said the R.CMP has still not 
received a copy of >teslop'3 report but he * 
said the '.'contents' bfj.it.' as- reported try 
yesterday's Free Preis'' do :; hot surprise 
.him. 

"We've been' aware of '(Satanic; acfiVI-' 
ties in the rural areas for some time and 
have investigated numerous incidents." he 



. said, refusing to give specifics. :•■ '■■*■:.■'■; 
'"It's a concern }o us although I would 
"■stress "that- (the Criminal activity) isn't 
^widespread," he said. ■ ! ■. " ■. ' ■ ,: 
; "' Sa-gster said the} force has done what it 
;.can to educate its fflembers in the outlying 
! detachments oa Mat to look for and any 
■ suspected inddents-qf illegal Satanic activ- 
ity are rerxirteCnFffiJRCMP headquarters in 
"-Winnipeg which ''coordinates* the Jnforma- 

sot, ■■■■■■■" ■ 

'' /'We've been.vetj! proactive' mtUrared 
and' have attempted id ■inform'' OUHmerri' 
be'rs through Straining manual and. a" .video 1 
whidi'has been 1 , s^rit 'lb a)i|ijth^'' : defach- 
ments,"' he. -said'! adding 1 a!-c"Oufse*'lri 

.Satanism,.is alsos.a i.standard, part. of 

SCMf mvesLigntors' training. 
- Sangster said the force also attempts to 
monitor"', the -movements of known cult 
members within the province as well 
.as.acrosg Canada and the U.S. . , .'. 

liVr Accordi!ng to Heslop's report, -Winnipeg; 
based Satanists have connections to over a 
dozen Canadian .cities from Vancouver to 
Halifax/-:;. ;.;',... ■..!.■■■, 

...'SangstlV sijd tfi^ManJtbbaf RCMP worB 
•closely #ith tithef police .forces ~ partlctlf 
lirfy those In' .Western. Canada — to track 
.the 1 ; movements of'; the .known cuJt'mem^ 
be'rs. 

■' l He said :ihe force is also a regular 
contributor ,to! Canadian. Intelligence Ser- 
vices Canada (CISC), which Is a national 
storehouse of information on organized 
crime groups in Canada. 

A spokesman for CISC could not be 
reached for comment. . 

: Sangster said the investigation of Satan- 
ic-related crimes is difficult becati'p the 
groups are rigidly controlled and there is 
only so much police can do to penetrate 
them'. , ■.; ■ •' 

'."We're very cautious of the Charter of 
kights when we do our investigation?.." he 
Said /''noting the charter guarantees free- 
dom of belief — no matter how biznire — 
and police cannot arrest someone for 
simply being a Satanist. 



5ER 2 1 EM" 






conference 
targets abuse 



^U-A-t ^-'/f . 



By Alexandra Paul 

The province will pull doctors, 
lawyers, teachers, social workers 
and government officials together 
this fall for a massive conference on 
Satanism and ritual abase of chil- 
dren 



held last December to assess the 
extent of Satanism in Winnipeg. Top 
top Family Services officials and 
child and adolescent mental health 
officials attended, she said. 
/See CRITIC page 4 



z^M^*r Critic demands 



continued' from page 1 



-"As well, Family Services Depart 
•rcmf.^inMrtwm -Tanice Little said 
vesterday the province is looking at 
a review of allegations of Satanic > q 

criminal-cult rituals in Winnipeg. - £J > J n|Yl 

Utile said the government nas <%* O T J+TI I S I II 
■been' quiefly tryingto combat ntual-. ^J {\ lji|i.JJ.)JXXJ. 
■ istic abuse of Winnipeg children 
since last year. .;.;.. " . ■. ■ 
■ She said -experts in Satanism,, 

including policei^social workers and 
psychiatrists -from outside .Manito- 
ba, will be'brdught to Winnipeg for 
■two days in November to train 400 
conference delegates; :■ :; >.^^. ..-,,. 
The delegates will be taught to 
identify, assess and treat children 
involved in ritualistic abuse, Lame 

•"It T s .an interdepartmental ■ ef- 
fort,", -she said, naming the lead 
departments as Health, Justice, 
Education and .Family'Services. 

•The conference will be the first o£ 
its size to be organized by the prov- 
ince, Little said. 

■A previous, smaller workshop was 








Jr 



%^ 



Little's comments were the re- 
sponse by the Filraon government 
yesterday on the findings of a secret 
police report on Satanism in the 

city. . .',' ... ' ■ •;■ 

' The 32-page report, completed in 
March by national Satanism expert 
and Winnipeg police Const. Russ 
Heslop, identified a criminal net- 
work tied to five local Satanic 

cults. 

Heslop stated the network is en- 
gaged in pornography, drug traf- 
ficking, child abuse, sexual assualts 
and possibly murder. . ... . ,... i • 

Known cult members number up 

to 150, come from all walks of life, 
and range in age from 13 to 50, the 
report says. 

A registered nurse, a restaurant 
manager and a high-ranking bank- 
ing official have been linked to one 
cult, it says. 

Little said the Heslop report is not 
the only indication the government 
has had of Satanic cults operating in 
Winnipeg, but she would not elabo- 
rate. 

"This is an issue the department is 

aware of," she said. 

"It is something we will take 
forward for a review with the new 
minister." 

Retiring Family Services Minister 



,_. ^o/- 



Charlotte I Oteson did not run the 
Sept. 11 provinical election and 
her post is expected to be filled next 

Little said it is up to Oleson's re- 
placement to decide, how to re- 
spond to the Heslop report and to 
calls this week by psychiatrist Dr. 
Colin Ross and social worker Rose- 
mary Somers for a task force on 
Satanic activity. 

At least one opposition critic, how- 
ever, accused the Tories of dragging 
their feet on the issue. 
, NDP family services critic Becky 
Barrett (Wellington) blasted the Fii- 
mon government for failing to throw 
Its resources into a full investigation 
of Satanic cult activities in Winni- 
peg- . L 
"Anytime there (s any suspicion 

of abuse, you need to act on it 
immediatelyU-you need to investi- 
gate it by putting human and finan- 
cial resour^s into it," Barrett 
said. 

Barrett, a ;soc^t worker and for- 
mer executive director of a housing 
program for abused women and 
their childrerj, said Satanism is not a 
new phenomenon. 

There are £tories of children dab- 
bling in Satanic rituals in Alberta 
and Saskatchewan, Little said. 

"It is not Something that has ap- 
peared miraculously," she said. 






1 3.SK 

force 
urged 
on cults 

By Allison Bray 

Satanism poses a real threat, but 

3 Manitoba lacks the resources to deal 
with the -problem, -a Winnipeg psy-_ 
chiatrist said yesterday. 

Speaking to about 70 school coun- 
sellors, teachers and administrators 
at a one-day conference on Satan- 
ism, Dr. Colin Ross said a multi-dis- 
ciplinary approach involving gov- 
ernment departments and law 
enforcement agencies is needed to 
fight the problem. . "",' , , '"'.' 
"The fact is it's there, it's defi- 1 
nite," Ross said of Satanic worship 
and cult-related crime. • * 

, But he said the resources to deal; 

-with -the '^iroblem^'^jncluding ^-psjg; 
chotherapists^with,;expertise in $&-■ 

.tanic '^csntsr'a^fsiirtt^TnoiHexis;; 

; -tent raManitoba;; ., ...... 

i- -"Jt's "Apathetic the ^ounr'af re? 

"sources available, for child -abuse in 
generaI,'but-whenyou add on Satan- 
ism.-; it's ' completely -'undefined,", 
he said.""-.' ■■ , ..\. 

..-:. Task force. - : r 

■."There just aren't people you can 

refer to—who are Satan counsel- 

iOtS. --■••---:•■■ 

Ross said the provincial depart- 
ments of Education,'"'-"Family Ser- 
vices, Justice and Health — which 
are sponsoring a two-day conference 
on the issue next month — should go 
a steplurther and esta b lish a task 
force to deal with Satanism,- - ■ ■--■•-— 

"We need some -sort of co-ordinal--.' 
'ed, -organized body," hesai<L~ — 
' As" ;well,-ihejsaid,-':municipal- ?and 
.provincial police . should be jestruci, 
tured to better investigate crime 
related to Satanism. * ' . 
--"Ross said the cost 'of -treating 
those who iia ve. been rheavily in- 
volved with Satanic -cults;i3.. enor- 
mous, .j. 

Tor "example, "nTliaMl7""cn^uTe& 
who have been severally sexually or 
physically abused — .which may 
occur in Satanic rituals — may de- 
velop multiple personal fry disorders 
that take years ofjnerapy._to.over; 
come. 



He noted the cost to treat 15 
women in, Manitoba suffering from 
the disorder — a severe form of psy- 
chosis in which separate personali- 
ties emerge as a means of coping 
with .severe traumajgr_abuse — .is. 
'more - than ^'"million, adding the 
average length of therapy is about 
four years. 

Ross said while some otherwise 
normal teenagers may simply dab- 
ble in Satanism for kicks and later 
drop it, the jury is out on how 
much psychological or emotional 
damage may result, or on what 
factors would cause them to get 
involved in the first place. 

Awareness session 

J"t just don't get it why a kid who. is 
pretty well adjusted would get in- 
volved in a Satanic cult and drink 
the blood of his friends from a 
vase,"he said. ' < 

"I just don't see many well-ad- 
justed kids getting sucked into it." 

Ross and RCMP Const, Kathy 
.King were invited to speak on Satan- 
ism and cult-related crime as part of 
a Satanism awareness session spon- 
sored by the Counsellors Association 
of River East, consultant Joan Tru-. 
byksaid. >.,< ■■ .*-■-...;«•■•.; ■■-.-.■ j v"'*-^ 

- Despite recent reports of Satanic 
involvement in the desecration of 
cemeteries in St. Boniface and West 
St -Paul, '.Trubyk said .the in-service 
.wasrplanned .;months '^ago./oiot ,in 
reaction to theevents.-vi-i-.r:^.;:^ 
.'i'i_?We're at an 'awareness stage," 
-she said. ""We're hearing reports and 
it's important ;for us to keep abreast 
of it" <--!/Z:~^~^^- >- L .~- 

.Trubyk said while teachers and 
counsellors are concerned over the 
growing reports of Satanism in Win- 
nipeg and North America, the issue. 
has not exploded at the school 
level. ' ■. .-•;—:• -- ■;■-*■-■■. 

■■"Ultimately, we need to know 
what's happening, maybe we need to 
know not to overreact," she said. 

'King said while police are aware [ 
of a certain amount'of dabbling or 
■"entry-level involvement" in SataiK 
ism in Manitoba, police have/no- 
statistics as to its prevalence. .,'.;_...,. 
: However, she said, now that lhe ; 
issue has, -come into the limelight;' 
Incidents may appear to be on .the 
rise in much the same -way that 
reports of child abuse .have. in- 
creased as awareness of the problem 
has grown.Il,- 



0C- 



rr- ^° 



vJ 



r. P. 




Satanic 
inquiry 



?3 






urged f^ I 

By Alexandra PauF <£^£ 

A doctor and a social worker 
who hear frequent confessions of 
ritualistic practices — including 
human sacrifice — from self-pro- 
claimed Satanists a.- j demanding 
a provincial inquiry into crimi- 
nal-cult activities in Winnipeg. 

"We -should have an attorney 
genera! task .force into this — ■ 
there's enough reality to justify a 
task force and it's serious," Dr. 
Colin Ross, a psychiatrist' and 
Canadian authority on multiple 
personality disorder, said. 

Social worker Rosemary 

See TASK page A 




"Task force needed, 
social worker says 



continued from page 1 

Somers echoed the call. 

Somers, fo rmer co-ordinator of 
Youth Victims Project— a joint 
city poSice, school and child and 
family services program — said 
child-welfare- officials have fre- 
quently discussed the need for a 
provincial task force into Satanic 
cults and street gangs. 

"We absolutely have to have 
this," Somers said. 

These (Satanists) are organ- 
ized so why on earth shouldn't we 
be — we're supposed to be the 
good guys." .. 

Ross and Somers wa nt Justice 
Minister Jim McCrae to order an ' 
inquiry into the -findings of a 
secret police study by Winnipeg 
Const. Russ Heslop, w ho spent a 
year documenting Satanism in 
Winnipeg for the department. 

The 32-page report detailed a 
criminal network tied to five local 

__ Satantic cults engaged in organ-, 
ized pornography, drug traffick- 
ing, child abuse, sexual assualt 

■ and possibly murder. 

They said that if such a task 
force supports Heslop's findings, 
then the province must forge a 
network of therapists, social 
workers and police to combat the 
cults. 
The province was silent on the 

- call yesterday ,-despite-a -report-' 

~~er's' repeated requests to" speak" 
with Premier Gary Filmon, 
M.cCrae and other officials. 



"What we are talking about is 
sexual abuse, physical abuse, 
emotional abuse and substance 
abuse." Somers said. „ 

She and Ross said they take 
Heslop's findings seriously. 

"At St. Boniface (General Hos- 
pital) we have heard reports 
about Satanists and their crimes 
in Manitoba, which include a 
whole variety of criminal prac- 
tices, including human sacri- 
fices." Ross said. 

He said he has heard confess- 
-ions from approximately 20 pa- 
tients who have told him for three 
years that they are involved in 
highly organized Satanic cults 
which are part of a- network 
stretching across North Ameri- 
ca. .. 

The confessions are uncon- 
firmed, but they support the find- 
ings of the Hesloo report. Ross 
said. 

He said many of the patients 
have histories of sexual and phys- 
ical abuse at home, making them 

susceptible to cult leaders who 
play upon their victims' minds to 
cultivate deviant behavior. 

"There are teenagers who are 
drinking each other's blood — I 
have direct statements by partic- 
ipants of "these activities," Ross 

- said." 

-— ' , Tney - do - "Speclfic"ritual's, 
drinking each other's biood, ritu- 
al sacrifices of animals." 



#w^^ 



Five-year-old tots 
of Satanist families 
'ritually abusefc 






By Paul Wiecek 

© Winnipeg Free Press, 1 990 

Children as young as five have . 
been "ritually abused" by . 
members of their Satanic families. 
who use them for sex and possibly 
even feed them raw animal flesh, a 
Winnipeg police, intelligence report 

says, v.i- -'-■-■ -'•■ ''■ - -<■ 

"There is evidence to suggest 
several cases of ritual child abuse 
have occurred within the city," . 
Const RussHeslop c oncluded.in.a. : 
report he submitted to Chief Herb. 
Ifrcphen last March. 
i In. one instance, the report states 
■ several children, including two ... \. : 
girls, five and seven,- and a young . 
' boy, were removed from -a- Satanic 
family — which included a senior : , 
bank -official and .a registered .^.v.-- . 
' nurse — ■ after allegations of .sexual 
^abuse were made. -■ '■_.-• 

■""■. "As the children were' removed 
' to-a -foster home/they-began to ■■." 
; disclose . definite Satanic 
experiences with indicative 
behavior,", the report-states, -i 
... "The children -were observed . 



eating raw flesh from a chicken, . 
klEing a family cat, chanting - 
slogans such as TCill her, Kill her,' 
(and) digging up decaying 
carcasses of family pets and other 
animals that were buried around 
the yard". '■'":■ 
• The report states the children 
also made numerous references to 
a "dead pit" where their "father " 
and uncle supposedly disposed of 
dead animals." ';' 

The report said the girls were 
^'terrified of the television' and the 
VCR.- ■ : -:**'■;'•■■: -'■." 

"'Some of their disclosures were, 
■that they had been filmed in" 
.various sex.acts with family 
members and that they had seen , 
■themselves doing 'dirty things' on 
TV (i.e. -video).". M':-- : ■,.- -:.Vr , 
--; Eeslop said nu merous ..:;..:..". , 
accusations have been made ••; :r- r ~ \ 
against one family (the report isn]t ; 
"clear 'if 'it's the'sarae"fafiiily)'but: . 
"To date, many of the accusations- 
.have resulted in Crown. opinion ,Ci. 
decisions indicating no charges due 
to the credibility of the young- r- . ' 
children."-'--.. . .■■- ■ ' --- ■ *•' : '' 



forces expert 
out of province 

Doctor to headprogram inTexas _ 



By Alexandra Paul 

Dr. Colin Ross, an expert on multi- 
ple personality disorder, is leaving 
Winnipeg to help head a psychiatric 
program in Texas. 

■ J M ^ happy atrorthe situation In 
Texas but I'm sorry to be leaving 
Ma nit oba," saW RessT'3'n associate" 
-professor at- the University of Mani- 
toba who practises at St. Boniface 

"Cengfal HnspM."- "'".".—..-"—'- 

^HelTmiss Winnipeg, buj_he_wnn.X .. 
"miss the Tuntling "shortages and ani- 
mosity he has faced from other men- 
tal health officials. 

"There are various reason for leav- 
ing but the main one is there is not 
enough support — clinical support or 
research-support — .for this area in 
Manitoba."' ' 

., He added that funding pleas to. the , 
Manitobalieafth Seryices_Coinm is- 
"slo n Cp r ' t wu ~y^TsTo~paylhe salary of " 
a research nurse have been ignored. 

Animosity from mental heaith pro- 
fessionals, including other psychia- 
trists, is another reason he's packing 
his books. 

"There is a large amount of hostil- 
ity by mental health professionals, of 
dissociative disorders and that's 
been a factor in my dt-cision to 
Ieave,"hesaid. 
Maiiy..psyjdiia f rH''-', psyrhokyia 



s and uthers don't believe in the 
existence of emotional trauma from 



nur 



urs£^ 

xiste ___ — 

"CrtnyTt'OOITaBuse; he'said'. " 

That's partly because their train- 
ing and society in general has ig- 
nored the phenomenon until recent- 
ly, Ross said. 

"The two major forces in psychia- 
try in the 201 h century, psychoanaly- 
sis and biology, have really excluded 
child abuse," he said 

He noted that the father of psycho- 
analysis, .Sigmund h'reud, dismissed 
stories of childhood abuse as neu- 
nrticfantasres. " "' 

Meanwhile other founders of lliv 
profession preached that mental ill- 
ness is caused by biological factors, 
Boss said. 



Neither influence leaves much 
room for environmentally induced 
disorders, he said 

He said Canada lags behind the 
United .States in recognizing emo- 
tional trauma associated with child- 
lioVnfabuse. 

_.JRuss said his departure Nov. J8 will 
give him a chance to advance re- 
search on multiple personality disor- 
der CMPD) and the emotional conse- 
quences - cif-'chiltihuod sexual-antf 

- physical aou^e-. ---- 

Ross, the author of a definitive text 
on MPD, will be working with a team 
of profession lis at the Charter Hospi- 
tal of Dallas, a private facility in a 
Dalla. Mjhurb. 

His work will involve two. in-pa- 
tient programs, one of whichls a 10- 
bed unit for MI'U patients and a 16- 
' bed unit for patients' in crisis Tronr 

■ Jtcxttrt! abt^c.— — 

.. "There are 12 in-patient units in the 
U S. and there are none in- Canada 
and no indications that theft is going 
to be one." he said. 

Rfl&iQ; departure is Manitoba's 
lns^.Cnrfc*lian Mental Health Assoc:-, 
atinn executive director Hill Martin 
said. 

Martin, iv h»i heads up the Manitoba 
CM 1 1 A, h.'iiird Nosh us a pioneer. 

— -Fur mh i j iii.it 1iL'*s'Rriin(i." Mtiri'iir 
said, predicting th.it bis patients and 
...many. . professional. allics.-ht:rc -veilL 
miss Ross 

"I bdttve Colin Is making an im- 
poitant coiitnbutiot: so lhar in five 
years time we will look back at if and 
say "['hat was a jimid beginning,' 
Martin said. 

Martm said he understands Ross's 
frustration with lean research grants 
antf animn-oiy from si >me profession- 
als ^ 

hut at thes.'imclime. patients have 
». fu^'tltt-ifsjiy renmrws-thwr'RmT*-- 
tlepart ute will leave n gaping hole, 
Martin said. 

"! (Ifiti'i know anyniie who Jut's (In- 
same kind of '.iork heilo*". " 



SefT. 3^ 







Somejscience, some fiction 

Tabloid' tricks MD for ouEof body experiences pirn* 

By Alexandra Paul tabloid in a story headline J: "One in think." 



By 

ENQUIRING minds wanted to 
know. 
And a respected Winnipeg 
psychiatrist says he was tricked into 
giving National Enquirer readers the 
goodson out-of-body experiences. 

~ geetOF-force d"t o-leave/3— --■-■• 

Dr, Colin Ross, an expert on 
multiple-personality disorder and 
childhood abuse, is quoted in the 
Scp^3 7 issue of the supermarket 



three people have left their bodies ■ 
& then returned." 

"The guy phoned me and identified 
" himself as a science writer so I didn't 
know it was going to be in there." said 
Ross, who works at St. Boniface 
General HospitaJ and is an associate 
...prafessor.„.-at..-,.the....UniveES4SiL,-Ji[_ 
Manitoba. 

The article quotes Ross as saying 
"Out-of-bodv experiences are much 
mors common than most people 



The article, which, has no byline, 
cites two instances — oneof a woman 
who left her body after plugging 
from a third-storey balcony and 
breaking her pelvis nnd the other of a 
man who floated outside himself 
during heart surgery. 

— -"-Those "t wo^-eX(tmpJe;^'*re— mud* 
up." Ross scoffed. "But the "statistics 
are accurate and 1 did do the study." 
; Ross said he led a team which 

See OUT-OF-BODY page 4 ■ 



Out-of-body experiences article - 
'not bad, 'psychiatrist insists 



continued from page! 
interviewed LOSS men and worn- 
e n, ifi cri 18w7ft . fr «™-^ ""' ip *ff ' — 

Each respondent was asked 28 
questions, inc1uding_w_het_her rhey 
ha've'Had out-o7*body experienc- 
es. 

That question was: "Some pco 
pie have the experience of feeling 
as though they are standing next 
to themselves or watching them- 
selves do something and they ac- 
tually see themselves as if they 
are looking at another person. 
Mark the line to show what per- 
centage of the time this happens 
to you (from zero per cent to 100 
lercenn;* 

He said 302 of the respondents 
— 28.6 per cent — reported at 
least one out-of-body experience. 

■This is how they came up with 
the figure of one in three people 
had some kind of dissociative ex- 
perwnce." Ross said. 

All the respondents said they 
were-akrt,~owake-aj!d not under 
the influence of drugs or alcohol 
during the events, 



Ross said he's not angry at lhe 
Enquirer for making up part of its 

^gfriry anH fniN "? to iH-ntify i'.SiiL 

to him in the interview. 

"It doesn't slay me." he said. "It 
was "not a bad article, not a sensa- 
tional article, aside frnm those 
two points " 

The study is part of a ground- 
breaking series on cases of sexual 
and physical childhood abuse in 
the general population. 

It was published in the Ameri- 
can Journal of Psychiatry last No- 
vember. 

It discusses coping mecha- 
nisms, called dissociative behav- 
■Hjrs. that are usually linked to the 
trauma of childhood abuse. 

Some findings that the tabloid 
left out include: 

U 47 per cent said they felt al- 
most as if they were two different 
people. 

Q Seven per cent hear voices 
more than 30 per cent of the time, 
suggesting that most people who 
hear voices frequently do not 
have schizophrenia. 



■ mi 

f i?ee 



r>^ 



2 Winnipeg Free Press, Sunday, October 7, 1990 

Officer won't speak o 
until reporter leaves room 




Hy Alexandra Paul 

A Winnipeg police officer refused 
to give a lecture on the evils of 
Satanism yesterday — until a re- 
porter got the heck out. 

A Free Press reporter was or- 
dered out of a lecture on Satanism 
yublorday to be given by national 
expert and Winnipeg police Const. 
Ruis Heslop at a Roman Catholic 
youth conference. 

A conference organizer announced 
a journalist was in the room sec- 



■pj*r 



onds before Heslop was to deliver 
his lecture, billed as a warning about 
Satanic activity in Winnipeg. 

Chatter among the approximately 
50 delegates in the packed room was 
silenced by the announcement. 

. 'That's her' 

The organizer, who did not identify 
herself, told delegates the session 
would not be held unless the reporter 

left. - ■■. ■ .-,.•■■ ■■■■ . 

Delegates began to murmur and 
one person pointed out the reporter, 
■ saying, "That's her." 



Outside the 'closed, doors at the 
lecture, another organizer said Hes- 
lop had requested the reporter's 
ouster at the last minute. : 

The organizer said Heslop was , 
speaking at the conference as a 
private citizen, but a conference pro- ' 
gram inviting media coverage iden- ; 
tified him as Winnipeg police offi- i 
cer. • j 

Heslop was not available for com- r 

'" ment. '" , , ,. 

Heslop authored an internal police 
r^pdrtjjomjietedjn March, that 

stated five Satanic cults with some 
150 members operate l» Winnipeg. , 
: The cultists are engaged in crimi- 
nal activity, including pornography 
3rug trafficking, child abuse and 
possibly murder, according to the 
.report. 
■ Hesloo was transferred to a com- 
JnSy rations post shortly after 
submitting his report. i 

('The Satanism lecture was the 
only session to be closed at the 
three-day church conference, cover- 
.. w 'g everything from sex education 

' and rock music to the Catholic inter- 
SetSloa of New Age spiritualism.- 
P A conference program showed 
H «lop was to deliver the Satanism 
feSS twice yesterday under the 

heading- "Satanism -Not what is 
happing in Vancouver or Miaou ; 
but right here in Winnipeg- , ■ 
^vTr brother, sister son gr 
daughter is a prime target, me 

^veSl^ple, interviewed betaj 
thfre^was barred, said they 

were not skeptical about reports of 
Satanic cults in the city. 

"We believe it is happening in 
Winnipeg and we want to know 
more " one middle-age woman, who 
did not want to give her name, 
said. 

"1 imagine those (parents) with 
children would be really worried," 
she said. 

Regina delegate Stephanie La- 
Belle, 18 said she is aware of similar 
Satanic activity in Medicine Hat 
and Regina. 

"I know of people who could Pe 
involved," she said. 




THE WINNIPEG SUN 



Are cnmesjtndabl^ 

ildren being 



against 




PIT format fQL§M^ 



IJlo r'-' L 



By ,VSA STAINSSY 
Vancouver S<in 

VANCOUVER 

he twists and turns are 
denser than an Agatha 
Christie plot. 

The phenomenon of rituai ibuse— in- 
volving horrific crimes and abuse against 
children, seemingly fer Satan — increas- 
ingly baffles and boggles the imagination. 
Alleged survivors of ritual abuse -ave ■ 
been poppins up at increasing rates across 
Canada in medical and counselling offices 
in recent years. 

Therapy uncovers unbelievable stones 
of murders, mutilation, human and animal 
sacrifices, rituals involving blood, excre- 
ment, semen, the breeding of babies jar 
sacrifice, violent sexual abuse of children, 
pornographic film-making, and acts be- 
yond the comoined imaginations of David 
Ijnch and Steven Spielberg. 

Until recently, such disclosures result- 
ed in survivors being labelled deluaed 
and ill. Now, professionals such as ponce, 
social workers, educators, counsellor;, 
Crown counsels and psychiatrists, are 
stalling to listen. 

But the spectrum of response swings 
wide — from people who believe sucn ritu- 
al abuse stories are absolute hogwasn to 
others who believe everything. 

Regardless of the divides opinion, ritu- 
al abuse persists. It is spawning work- 
shops, conferences, training sessions, sup- 
port groups for survivors and education 
awareness groups. 

cautious Rob Tucker, founder of 
l -the Council on Mind Abuse, in 
i Toronto, believes there is a core 01 

1 truth to the disclosures. 

"The numbers of cults aren't 
known " he says. "But numbers of adults 
coming forward in Canada are beginning 
to tip over a thousand." 

The biggest question in '.ne controversy 
is- If people are being muroered, wnere 
are the bodies and the evidence? Jut on 
the other hand-, how do all the survivors of 
ritual abuse, all across North America, 
come up with fairly consistent stories ot 
horrible activities' . 

Thi' believers say cults nave jopnisii' 
oatedway-. of destroying e-^nc^nvolv- 

ing Durnm* in industrial ovens. ™™ lh f- 
[■•in- "accidental" house fires, grind! ng up 
or eii'emicaily disposing of remains. 

They say culls nave memoers in ntghl/ 
oUced jobs assisting in the ooverups - 
,),.,;„!.• in police forces, insurance compa- 



nies, medical fields. They say "breeders" 
bear babies who are not reported to au- 
thorities, for sacrifice. 

Non-believers have other explana- . 
lions Thev sav the disclosures roil eel ■ 
psvchotic delusions, drug hallucinations, 
histrionic aiienlion-saesang, arcnetypai 
images from the collective unconscious 
or urban myths. • 

Others believe the stories are prompt- 
ed bv therapists asking leading ques- 
tions or that they are exaggerated inter-, 
p relations of Christian zealots. 




Colin Ross, a psychiatns 
at St. Boniface Hospital 
in Winnipeg, believes rit- 
ual abuse, as described 
bv survivors, does occur. As an expert in 
the Held ormultiple personality disorder 

— a controversial new area in psyemntry 

— Ross has come across a Pandora's box 
of ritual abuse disclosures. 

The disorder is believed to be caused 
bv exreme trauma during childhood. 01 
the estimated s.iXO people in North Amer- 
ica who have been diagnosed with tne dis- 
order about one-quarter to one-third nave 
ritual abuse memories. He esu mates Jt 
least 500 cases of the disorder in Canada. 

"These are stories people are hearing 
all over North America and it does seem 
impossible and unimaginable, but tne sto- 
ries are consistent," ne says. 

"Cannibalism has existed in all rdnds of 
cults throughout human history so lit not 
inconceivable that the human race could 
do that, 





"AnTnlenial report leaked from tne .vin- 
nlpeg police department to the Winnipeg 
Free Press last month shows the depart- 
ment is aware of 159 satanic cult members 
in that city. 

the Winnipeg area recently, 
someone opened a crypt, violat- 
ed the bc:y. and took body 
parts including the head. 
"It wasn't the workoi some 
ldds." says Deputy Police Chief J^ Gal- 
lagher. 

Edmonton police aetective- Ken 
Montgomery, in a recent interview ;r 
the Catholic newspaper, Western 
Catholic Reporter, said as many as 
five satanic cults are operating m 

I h 'i I i* i 1 7 

Pulls have not b,en involved in Known 
criminal activity but police say they xnow 

of teen suicides resulting irom euK.n- 

volvernent. ., 

Vancouver police, now/cr, repoi . noth 




Danlela Caatss 1: tne toundar ol Vancauver-nasc 

inf unusual in cult activity in that city. 

'"If anyone has such information, : ur*c 

thorn to come forward. Wc- depend on tne 

public for information," says Sgt- -iw 

C wiper. 

Ln Vancouver, Lh. : 111 tuai Abuse Aw:ire- 

ness Networ/.'THAANS), a luppoit -roup 




t . . VHF-WiNNIPUG SUN ^uiui.u:. 0<:!^N:r 1 

an cop 

BkimecLfoj- 
fearof_cidis 

By MICHELLE BAILEY 
For Tha Sun 

he author of a police re- 
port claiming satanic 
cults exist in Winnipeg 

says he's been taking "heat" 

since the document was 

leaked to the public last 

month. 

"I got the message all of the time that I 
am the reason why all of this (fear of cults . 
in Winnipeg) has come up," Const. Russ 
Heslop said yesterday. "IVe been under a 
considerable amount of heat." 

Heslop, a former youth division offi- 
cer who spent a year researching and 
writing the controversial report that gar- 
nered national headlines, made his com- 
ments during a speech at a Catholic 
youth conference. 

After the presentation, the officer — 
who had asked organizers not to allow 
media into his seminar — refused to 
elaborate on his statements or speak to a 
Sun reporter. 

A police official couldn't be reached 
to comment yesterday on whether Hes- 
lop — transferred to community rela- 
tions duties last spring a tier completing 
his report — was speaking with the ap- 
proval of the department. 

After the report was leaked to the 
media, police officials — who denied 
Heslop's transfer was a punitive mea- 
sure _ downplayed the validity of the 
document, which claimed satanic cults 



l','<)0 




Sacrlllca band's music only 'promotes se 

in Winnipeg are involved in criminal ac- 
tivity from prostitution and drug traffick- 
ing to murders.. . .■ ..■•.■ 

During his'speech yesterday at the 
Young Catholics Challenge the '90s con- 
ference, Heslop didn't, discuss the docu- 
ment or its allegations, limiting his com- 
ments to satanism in general... ■■ 

Calling the, practice "seductive and 
frightening," Heslop said society has to 
realize satanism is a multi-billion-dollar 

industry. '■'. ' : --'.' -.-. ;■'■"' . 

"People are cashing in on satanism 
and are promoting it through movies, 
music, clothing, printed media and other 
forms of literature. 

"And young people are the most sus- 
ceptible because they are the ones who 
are targeted by these multi-billion-dol- 
lar industries.'-' ::■:''■.'■ . 

Reading from heavy metal lyrics by 
bands with names such as Sacrifice and 
Exodus, Heslop said young people are 
learning and listening to "more ot this 
than to their teachers." 

"People will listen to this for four or 



x, drugs and Ihe occult,' says cop. 

five hours a day, which is longer than 
they are in school," he said, adding the 
music only "promotes sex, drugs and the 
occult. 

"They are getting a message in there, 
whether they like it or not." 
. While people in the audience gasped 
in disbelief, Heslop said individuals in- 
volved with the occult believe in the 
Bible,- God and Jesus — but choose to 
follow Satan. 

"Some people have a hard time be- 
lieving in heaven and hell. Satanists be- 
lieve in hell. They know they are defi- 
nitely going there, unlike those who 
hope they will go to heaven." 

He said the only way to understand 
satanism is to understand Christianity. 

"II is important to be convicted in 
your own beliefs. There is hope in all of 
this and it comes through education, 
awareness, and net being afraid. 

"Fear is a product of ignorance — 
and we could remove a lot of fear from 
not being so ignorant." 



-^ 



1 ' Q 3 / 9 7 12:43 ©21)4 943 2003 ADMIN ©OOl/ooj 



Manitoba Government < ^ 

SEWS RELEASER 



Manitoba 



y 



information Services, Room 29, Legislative Building, Winnipeg, Manitoba R3C WiL^^X Telephone: (204) 945-3746 



November 27, 1990 



SATANIC CULTS FOCUS OF 
PROVINCIAL INSERVICE 



Ritual abuse and youth involvement in satanic cults will be the topic for 
a provincial government inservice, believed to be the first of its kind 
in Canada, November 29 - 30 in Winnipeg, Health Minister Donald W. 
Orchard has announced. 

"Investigation has revealed that children and adolescents who have been 
victimized by ritual abuse, and the active involvement of troubled 
children and teens in satanic cult activities can leave significant 
emotional scars which may form the basis for mental health disorders," 
said Orchard. 

"It is important the government receive accurate information and strike 
new strategies regarding the identification, assessment and treatment of 
children and adolescents involved in satanic cult activity." 

Professionals providing youth services in the departments of Health, 
Family Services, Education and Training, and Justice will attend the 
inservice which will co-ordinate the training of government staff from a 
cross-departmental perspective, A limited number of observers from the 
police, RCMP, and clergy will also be invited to attend. 

Speakers include some of the top experts in North America: Dr. George 
Fraser, Director of the Anxiety and Phobic Disorders Clinic, Royal Ottawa 
Hospital; detectives Wilson and Wikersham of the Denver Police 
Department; Louise Edwards, Registered Clinical counsellor, B.C.; and 
local speakers giving psychiatry, police, counselling and pastoral 
perspectives / fy 4- _ 

- 30 - 
Contact: Leanne Boyd, Mental Health Services, 945-5447 



Winnipeg free Press, Saturday, December 1. 1990 "1 3 

Extent of Satanism 
overblown, expert says 



By Broiida Suderman 

Only half (hose people who claim 
io tw involve;! in Satanism actually 
ixinicip^ro in hard-core cult rituals, 
in Ouaw a psychiatrist who special- 
izes in pwit-traumatic stress disor- 
Jora said yesterday. 

"We're 'not believing everything 
thai is yning on, but something is 
ijoirig on," Dr. George Fraser of the 
Royal Ottawa Hospital said at a 
media briefing. — 

During the final day of a provin- 
cial in-service on Satanism, Fraser 
presented findings from his work 
with 25 adult patients who have 
suffered some form of childhood 
abuse. 

The meetings with staff from the 
departments of Health, Education, 



There'siots 

o f tricker y 

going_on! 



Family Services and Justice were 
closed to the media and the public to 
allow for open discussion, organizer 
Leanne Boyd said. 

"We think it's really important 
that the media gets the story out, but 
it is also important for staff to deai 
with confidential matters freely," 
she said. 

Fraser said 12 of the 25 patients 
were probably involved in cult activ- 
ity through their family connec- 







tions, and another five participated 
in gang rituals described as Satan- 
ic. . , : '.. i ■. i ■ . . 

The others either iied or just Ima- 
gined the rituals, he said. 

But despite 'his findings, Fraser 
doesn't have any real proof of wide- 
spread satanlc activity or ritual 
deaths. :. . 

"I .think there's, not a lot of 
bodies," he said. 

"[ think what's happening is 
there's lot of trickery going on." .- 

Perverse sexual activities are' 
often cloaked under', the guise of 
Satanism to gain credibility,' he.' 

Said. ':'. '-I? ■■>,•;'.■ it; •■."■ t V ■..■■:}," ;! 

■. "We have'a 'group in society that 
gets together for sexual gratification 
and sexual perversion," Fraser 
^aid, adding money, not devil-wor- 
ship is often the motive. ,. ■, .. _ 
;. ( ,!'I think it's just a fantastic co- 
verup." ,...,.-;. - . 

' But despite his skepticism, Fraser 
said claims of abuse through Satanic 
ntuais can't be simply dismissed, j. 
1 ''Those of us who are looking at it 
are trying to be ve ry cautious, an d 

study it," he said. 
■ A government committee will con- 
tinue to deal with the issues Fraser 
and other workshop speakers raised, 



She. acknowledged Satanism and 
ritual abuse are real in Manitoba, 
but it's impossible to say how wide- 
spread the activity is. 

Fraser commended the Manitoba 
government for sponsoring the two- 
day workshop, and said govern- 
ments should establish some type of 
agency to investigate rumors and 
charges of satanic activity. 

"Even if only half of their stories 
are true, these people need help," 
Fraser said. 



Satanic abuse services 'cut up : 



By Alexandra Piiul 

l-Yagrner 



hin- 



t l'"i';iyrnontod services are 
during tht: rescue of children abused 
in Satanic rituals, the province's top 
a chiLl-proteclionexpertsays. 
Vn "it's bizarre — the whole thing Is 
'Sfc ^ ut "P." Cll[ld Protection Centre di- 
rector Dr. Charlie Ferguson said. He 
said city police, provincial RCMP and. 
^ a handful of medical experts can't 
s< stem to work together. 
^- -None of the disciplines make a 
connection and they can't find a siru- 
C) atinn that fits into their criteria," he 
if said, referring to differences be- 
y> tweeii the jurisdictions of the experts 
<*' and their varied definitions of ritual 

abuse. , . iU „ 

Ferguson said the tragedy ts that 
- he suspects Satanic rituals were to 
blame for some mysterious child- 
abuie cases he's seen since 1970. 

Probably the worst offender in the 
organizational ciiaos is the city po- 
lice, he said. , 

"'1 he official stance of the police 
department is skepticism," Ferguson 

' ' VWinnip^f nniife won't even run- 



nineg. 

''I ft 

sait 



firm to him the recent assignment of 
two officers to ritual abuse cases, he 

said. 

Ferguson said he tried as early as 
last winter to contact police but an 
appointment fell through with Const. 
Russ Hesiop, who co-authored a re- 
port on alleged Satanic crime in Win- 

e didn't show up," Ferguson 

'Ferguson said he's impressed with 
the work of RCMP child-abuse unit 
Const. Kathie King but she can't help 
his medical team in Winnipeg. t 

"She works in the country and she s 
not aware of any city cases" he said. 

Within the medical field, the divi- 
sions are just as wide. One of Cana- 
da's foremost authorities on dissocia- 
tive behavior triggered by abuse is 
Winnipeg psychiatrist Dr. Colin 
Ross. But Ross might as well be 
across the continent from Ferguson 
instead of across the city. \. 

"He works primarily at St. Boni- 
face (General Hospital)," Ferguson, 
who works at Health Sciences Cen- 
tre, said. "We have no significant con- 



nection with him," he said, adding 

• Ross's work is with aduits, not chil- 

, dren. 

' ' Youth division Insp. Lou Spado 

' stressed that the appointment of two 
■ sergeants /from the child-abuse unit 

' to handle ritual abuse is a part-time 
assignment. But he said that while 
there's no proof of Satanic crime in 
Winnipeg, police are taking the 
threat seriously. 

King from the RCMP said : "We 
haven t identified anything full- 
blown but we'd be very foolish to say 
this never happens," King said au- 
thorities are undoubtedly missing 
cases because they don't know what 
to look for. 
"We may not be able to point to a 

u case and say 'That's ritualistic abuse' 
"she said. 

Noting literature reviews' state rit- 
ualistic abuse is mainly emotional, 

■' King said: "It may not be something 
we can point a finger at." She also 
called for a co-ordinated "sensible" 
nnprnach to tackle the issue. 




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Man accused of rape may have 
multiple personalities, trio! jSld 



By Kevin Rollason 
I J iv Courts Reporter 



ANOTHER PERSONALITY 
belonging to a man accused ut" 
raping two teenagers and 
leaving them bound with wire could 
be responsible for Che crimes, a psy- 
chiatrist testified yesterday. 

Dr. Colin Ross, a former Winni- 
pegger and expert on multiple per- 
sonality disorder, said Edwin Den- 
nis Proctor exhibited telling symp- 
toms of the disorder when Ross in- 
terviewed Proctor for 7 1/2 hours in 
19S6. 

But he said he wasn't able to con- 
firm the diagnosis because the Men- 



tal Health Review Ooard wouldn't 
pay tor the additional 10 to 20 hours 
he needed for a definitive diagnosis. 
"It would have been easier to 
spend a few thousand dollars in- 
stead of the millions which have 
probably been spent on him over the 
years," Ross told the seven-man, 
five-woman Court of Queen's Bench 
jury. 

He added that if Proctor is suffer- 
ing from MPD he's not receiving 
proper psychiatric treatment. 

Proctor, 42, has pleaded not guilty 
to two counts of attempted murder, 
two counts of rape, two counts of 
confinement and one charge of bug- 
serv. ■ 



Court has been cold that two hitch- 
hiking 15-year-olds were sexual !v 
assaulted by Proctor on Oct. IS/ 
1979. 

The teens, both now 30, said they 
were each raped by the gun-toting 
Proctor, who abandoned them in 
separate places outside the city af- 
ter leaving them unconscious and 
bound with wire around their necks, 
hands and feet. 

Ross said the two internal voices 
Proctor claims he hears — including 
one called the Black Angel which en- 
courages him to commit suicide and 
harm nurses —-are a symptom of the 
disorder. 



4</ ^ 

_ he said Proctor's history 
vi childhood abuse and amnesia are 
also typical of people with MPD. 

Under questioning by defence 
counsel Saul Simmonds, Ross said 
he would find it "unbelievable" if 
Proctor was faking his svmptoms 
during the almost 15 years 'since his 
arrest. 

"He'd have to be an extremely 
good actor and not have slioped up 
through the years," Ross said. 

"He would have had to have 
knowledge about multiple personal- 
ity disorder greater than the psychi- 
atrists examining him in 19S0." 

The trial continues. 



۩\?Y 



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STATE OF MINNESOTA 
COUNTY OF RAMSEY 



Vynnette Ann Hamanne, 
Kenneth Earl Hamanne, 
Adeana Ruth Hamanne, 



IN DISTRICT COURT 

SECOND JUDICIAL DISTRICT 

File No. C4-94-203 



Plaintiffs, 



vs 



Diane Bay Kumenansky , M.D., 

Defendant . 
a-******************************* 

TRANSCRIPT OF PROCEEDINGS 

The above-entitled matter came on for hearing 
before the Honorable Bertrand Poritsky, Judge of District 
Court, on the 25th day of July, 1995, at the Ramsey County 
Courthouse, Room 1380, St. Paul, Minnesota, commencing at 
approximately 9:00 o'clock a.m.; 

The defendant appeared through her attorneys, David 
waxman, Esq., Eric Wein, Esq., 120 South Riverside Plaze, 
Suite 1200, Chicago, Illinois; and the plaintiffs appeared 
through their attorneys, Edward Glennon, Esq., R. 
Christopher Harden, Esq., and Christopher H. Yetka, Esq., 
4200 ID Center, 80 South Eighth Street, Minneapolis, 
Minnesota, at said time and place the following proceeding 
were had: 



cnr n-P(.ir.;T?c"Ti DcnnnffOf r nr* i onn on 1 o n C ,~ - i cnn im r o 1 "J 



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WITNESS 



Dr. Colin Ross 



WA = Mr. Waxman 
B = Mr. Barden 



EXHIBITS 



EXH-22 
EXH-167 
EXH-168 
EXH-169 



r N D E X 



DIRECT 



WA-3 



CROSS REDIRECT RECROSS 

B-73 WA-167 B-177 
179 179 



MARKED 

38 

41 

47 

136 



OFFERED 

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47 

136 



RECEIVED 

37 

41 

48 

137 



n ^ r* n — r -i -.->'->/- 



rtt r" "i i ^ O 1 *7 



1 MR. WAXMAN: Good morning, Your Honor. We'd 

2 ask Dr. Ross to resume his testimony, please. 

3 THE COURT: All right. Dr. Ross, you're 

4 still under oath. 

5 THE WITNESS: Okay. 

6 THE COURT: You may be seated. 

7 THE WITNESS: I was gonna do self-serve. 

8 Thanks, Judge. 

9 CONTINUING DIRECT EXAMINATION BY MR. WAXMAN: 

10 Q Dr. Ross, when we finished the day yesterday, you were 

11 discussing the history of the study of multiple personality 

12 disorder. And you indicated that there was a significant 

13 drop off in the amount of study and the amount of 

14 publishing on the disorder through about the 1960s into the 

15 70s. 

16 A Correct. 

17 q Would you pick up at that point on the course of the 

18 history of multiple personality disorders? 

19 a Sure. The dissociative disorders are dropped out of sight 

20 really in 1905 or so because of a variety of different 

21 factors. And then the curve stayed down really flat. 

22 There's only a handful of publications per year until in 

23 the entire western medical literature. And then the curve 

24 started to grow up again, especially late '70s, and then 

25 really take off in the '80s. So there appears to be four 



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DR. COLIN ROSS 



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Q 



Q 

A 



A 
Q 



Basically. And couple of radio interviews, two or three 
radio interviews, not a great deal. 

Okay. Now, you've also written a book, a proposal, called 
CIA Mind Control ; isn't that right. 

THE COURT: What was the title? I missed it. 
MR. EARDEN: It's called CI A Mind Control . 
THE COURT: Okay. Thank you. 
(By Mr. Barden ) Is that listed on your resume anywhere? 
No. It's not a publication. It was just a book proposal. 
It's about two to three years old now. 

Now, isn't — you had talked about when you left Canada to 
come to the states. Isn't it in fact true that you had 
some serious problems with a psychiatric community in 
Canada? 

No. It's not true. 

Now, I would refer you to a — to a newspaper article that 
was published in Canada. I think it's called the Winnipeg , 
Free Press published September 24, 1991. Are you familiar 
with that particular article? 

MR. WAXMAN: Objection, Your Honor. I object 
to cross-examination by smear. If there's something going 
on, it should be disclosed. We should talk about it. 
THE COURT: Approach the bench. 
MR. BARDEN: Is this a preach for a legal 
objection? 



nrnnnTCn' 1 run 1 ...p. nn -P. 1 1 .... 1 17 f, or- 1 - ^ 07 - S 1 2-fiK 1 7 



DR. COLIN ROSS 



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Q 



THE COURT: That's not an appropriate 
objection, Mr. Waxman. I think you know that. 

(WHEREUPON, a discussion was had at the bench 
not recorded by the court reporter.) 

THE COURT: Mr. Barden is withdrawing the 
question and will proceed, excuse me, as indicated at the 
bench. Now, go ahead. Rephrase the question. 
{By Mr. Barden) Do you recall a newspaper article in the 
Winnipeg Free Press dated September 24, 1991, in which you 
were interviewed? 

No. I was interviewed by the Free Press a lot of times. 
There's a lot of articles about me on a wide range of 
topics. I don't remember that particular one. 
Okay. Would it refresh your memory if I — well, I will 
just read you the quote from the news article. 

Okay. 

See if it refreshes your memory. If not, I will show it to 

you. 

A Okay. 

MR. WAXMAN: Objection. Shouldn't the 

witness be able to see it first. 

THE COURT: Not necessarily. The objection 

is overruled. 
q (By Mr. Barden) I'd be happy to. Now, in the article it 

says, "Animosity from mental health professionals including 



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other psychiatrists is another reason he's packing his 
books." Quote, 'There is a large amount of hostility by 
mental health professionals of dissociative disorders and 
that's been a factor in my decision to leave' unquote, he 
said, period." 

A Was there a question about that? 

q Do you recall making that statement to the press? 

A I don't directly recall making that statement. I'm not 

contesting that I made it at this time that it's reasonably 

■accurate . 

THE COURT: You say it is reasonable? 

THE WITNESS: I have no reason to believe 
that it's not. I don't remember the interview or 
specifically what I said. It could be an accurate quote. 
It should be an accurate quote. It's possible I said 
something to that affect. I just don't have a direct 
memory of that particular interview, which is already four 



years ago. 



Your Honor? 



MR. 



BARDEN: May I show this to the witness, 



first 



THE COURT: You may. 

MR. WAXMAN: May we see it first, Your Honor? 

THE COURT: Yeah. You have a right to see if 

MR. WAXMAN: Thank you. We have no 



SOUTHWES': 



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DR. COLIN ROSS 



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objection, Your Honor, as long as we get a copy so we can 
cross in the parts that are not being asked. 

THE COURT: Very well. If one isn't made, 
I'll just ask counsel to supply Mr. Waxman a copy. 

MR. WAXMAN: Thank you. 

(By Mr. Barden) And the question is, just having read 

that, does that come back to your memory now? 

No. I don't specifically remember making that statement in 

an interview, but. 

Okay. 

But I may have made a statement. I also, quite frequently, 

get misquoted and misrepresented. So it may be accurate. 

It may not. 

But you don't deny that there was a lot of — a lot of 

hostility? 

Right. That's true. 

Okay. And you don't deny that you may have made the 

statement? 

I certainly may have made the statement. 

Okay. Now, isn't it in fact the case that a number of your 

theories are considered very controversial in the 

psychiatric world? 

Yes and no. 

And that a number of your theories have generated, as this 

quote says, "A large amount of hostility by mental health 



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Q 



professionals"? 

MR. WAXMAN: Objection. The article does not 

say that his theories have caused the animosity. 

THE COURT: The objection is sustained. 

Wait. There's no question. 

THE WITNESS: I'm sorry. 

THE COURT: Go ahead, Mr. Barden. 
(By Mr. Barden) Isn't it true that your theory has 
generated a large amount of hostility in the large — 

MR. WAXMAN: Asked and answered. 

MR. GLENNON: — mental health profession? 

THE COURT: Well, not quite that. 

THE WITNESS: Okay. It's not -- should I 



answer? 



THE 



COURT: Yeah. The objection is 



overruled. 

THE WITNESS: It's not true that my theories 

have generated hostility. Rumors about my theories have 

generated hostility. Those rumors don't accurately reflect 

m y theories I actually have ever held or have actually 

published. So the hostility is toward the dissociative 

disorders as a general field. There's been a lot of 

controversy and hostility towards them, which would have 

occurred if I never existed. It's not hostility towards 

me , Colin Ross, or my personal theories. And the theories 



L_ 



i -^ I i T r 



rn-r r~jn con 



STATUTORY DECLARATION of Karen Ann Perchotte and John Yvon 
Perchotte 

Made this »2 *f- day of May, 199^ 



Karen Perchotte 
John Perchotte 
Box 114 

Group 327, R.R. 3 
Selkirk, MB. RiA2A8 

Tel: 204-757-2500 



STATUTORY DECLARATION 

We, Karen Ann Perchotte and John Yvon Perchotte, are married and reside at R. R. 3 
Selkirk, in the Province of Manitoba, do hereby solemnly declare: 

1 . That in 1992, our married daughter Corina Rennie(nee Perchotte) at age twenty-six(26) 
commenced a course of therapeutic marriage counseling under the care of counselor 
Keith McKinnon, employed with the Government of Manitoba, in the Province of 
Manitoba. 

2. That the Government of Manitoba counselor Keith McKinnon suggested to our 
daughter Corina in 1992, that she had all of the signs of having been sexually abused and 
that she(Corina) may have repressed these memories, and that the reason he(Keith 
McKinnon) knew about these signs of sexual abuse in others was because he(Keith 
McKinnon) himself had been sexually abused as a child. 

3 . The Civil Service Commission counselor Keith McKinnon then proceeded on a course 
of therapeutic counseling to recover the traumatic childhood sexual abuse memories that 
our daughter believed that she(Corina) had blocked out of her mind or repressed. 

4. That in 1993, our daughter, Corina Rennie(nee Perchotte) believed that she was in love 
with the Government of Manitoba counselor, Keith McKinnon, and that he(McKinnon) 
would be leaving his(McKinnon's) wife to be with our daughter Corina. 

5. That in 1994, our daughter believed that her marriage and emotional problems were 
caused by childhood sexual abuse memories induced or implanted by the Government of 
Manitoba counselor Keith McKinnon; memories of traumatic events that never 
happened. 



6. That in 1994, our daughter, commenced a course of therapeutic memory recovery 
counseling under the care of sexual and ritual abuse specialist Judy Hill, at the City of 
Winnipeg, in the Province of Manitoba. 

7. That in June, 1995, our daughter, Corina Rennie(nee Perchotte) confronted and falsely 
accused her father(John Perchotte) of sodomizing and sexually abusing her(Corina) 
during her childhood. 

8. That the fraudulent false memory creation therapeutic counseling first introduced into 
Manitoba in 1985, by Dr. Colin A. Ross, and which repressed memory recovery therapy 
was practiced by Keith McKinnon and Judy Hill in the counseling of our daughter 
Corina, has devastated our family and we will seek whatever relief that is available. 



Declared before me at the 
City of Winnipeg, in the Province 
of Manitoba, this J? < / day 
of X%l~, ,1-996. 

George Bergen ■' j ^-&^-yf y U^ g ^/^-- 

Commissioner of Oaths in and for the 
Province of Manitoba. My Commission 
expires March 26, 1998. 



Declarants: 

'a***; /hw suttcsfe 
aren Ann Perchot 




tL^C— 




John Yyt>n Perchotte 



Huff Investigation & Polygraph Services 



449 Provencher Boulevard 
Winnipeg, Manitoba, Canada 

R2J 088 

Telephone (204) 237-6006 

Fax (204) 231-0905 



December 7, 1995 



Mr. John Perchotte 

Box 114 Group 327 R.R. #3 

Selkirk, MB R1A 2A8 

Attention: Mr. Victor Bargen 

Dear Sir: 

Re: Polygraph Exam - John Perchotte - Your File # 95/1270 

On Thursday December 7/95 at 10:02 a.m. the subject John Perchotte attended to my office for 
the purpose of obtaining a polygraph examination with respect to allegations of sexual assualt on 
his daughter Corrina. 

The writer conducted a modified zone test series "A" with the following relevant questions being 
asked of the subject. 

5) Did you commit any sexual acts with Corrina at any time? No. 
7) Have you ever done anything of a sexual nature with Corrina? No. 
10) Did you ever sodomize your daughter Corrina? No. 

After examination of the charts the writer is of the opinion that the subject is truthful and he did 
not engage in any sexual acts with his daughter Corrina at any time. 



Yours truly, 




LH/jb 



c.c. Redekopp & Bargen 
Barristers & Solicitors 
1727 Henderson Hwy 
Winnipeg, MB R2G 1P3 



Curriculum Vitae of Lome Huff 



1961 Joined R.M. of Fort Garry Police Dept. as a constable 

1962 Graduated from city of Wpg Police Recruit School 
General uniform patrol handling all types of calls 

1966 Acting Sergeant in charge of shift of some five men, responsible for all activity in the 
R.M. of Fort Garry 

1967 Acting Detective for Fort Garry 

1968 Promoted to rank of detective. Involved in all criminal investigations, court officer 
responsible for the laying of charges 8c transporting prisoners from Vaughan Detention to 
Provincial Judges Court 

1974 Transferred to Juvenile Division downtown Safety Building on Amalgamation of all 

forces - Responsible for all investigations involving Juveniles and emphasis on all types 
of sexual assaults 

1976 Transferred to Vice Division - Prostitution, Gaming, Drugs and LCA enforcement 

1977 Transfer to Detective Division - Public Safety Building into Crimes against property and 
Arson. Worked on all types of criminal cases, Break, Enter & Theft, Arson, Murder, 
Rape, Robbery, Assaults. Also acting Sergeant in charge of fifteen to twenty detectives, 
responsible for co-ordination of all criminal offenses and detention of suspects 

1981 Selected as the first polygraph examiner for the Winnipeg Police Dept. Attended to 
Canadian Police College in Ottawa in Sept of 1981 - Graduated Dec. of 81 with degree in 
Forensic Polygraphy 

1982 Sergeant in charge of Polygraph Section, conducting all polygraph examinations 
including pre-employment 

1983 Promoted to rank of Sergeant level #1. continued on Polygraph 

1986 Sergeant in charge of special units for Break 8c Enter and Bank Robberies , in charge for 
squad of twenty detectives 

1986 Sergeant in charge of District #6 Detectives, squad of 8 men responsible for investigation 
of all criminal matters in Dist #6 

Jan/87 Retired from the Police Department as Sergeant level #1 after 26 years of service 
Feb/87Startcd my own company Huff Investigations & Polygraph services conducting all types 
of polygraph examinations and criminal & civil investigations for many law firms in 
Wpg, Calgary, Vancouver, Montreal Rcgina & Kcnora Ontario. Investigations for 
numerous Insurance Companies, and Businesses, Government and the Law Society of 
Manitoba 
1980 - To 

1987 Lecture to all police recruits & senior officers - City of Wpg Poiice Academy on 
Polygraph &. Interrogation & Interview techniques 

1982 Advanced course in Polygraph - Cdn. Police College - Ottawa 
1982 Lecturer to Man. Crown Attorneys Conference in Winnipeg on Polygraph use, 
Interrogation & interview techniques in the police field 

1982 Attended working Seminar on Polygraph with American & Canadian Polygraph 
Associations 

1983 Attended Can. Police Assoc, working Seminar on Polygraph in Winnipeg 



1984 Attended Can. Police College Polygraph School in Ottawa as a monitor and lecturer to 

Polygraph Course Trainees 
1984 Supervisor of Polygraph Field Training for Manitoba 

1984 Attended Can. Assoc, of Police Polygraphists working Seminar in Brampton Ontario 

1 985 Attended Can. Assoc of Police Polygraphists working Seminar in Wpg 
1985 Recipient of Service Award from Can. Assoc of Police Polygraphists 

1985 Submission to City of Wpg Council on values of pre-employment polygraph testing 

1986 Lecture to all in service officers Wpg Police on Interrogation & Polygraph 

1987 Lecture to Legal Aid Manitoba - use of Polygraph in Criminal matters 

1987 Lecture to Criminal Justice Chapter Manitoba on Polygraph 

1988 Lecture to Legal Secretarys Assoc, on Polygraph 

1989 Lecturer & Insurance adjustors conference in Brandon Man. on Polygraph use 

1990 Lecturer to Insurance Secretarys Assoc on Polygraph 

1991 Guest Lecturer for two day Seminar for the Brandon City Police Dept Crime Section on 
Polygraph, Interrogation & interview techniques on the police field 

1992 Lecturer to Manitoba Criminal Justice Chapter - Polygraph use 

1993 Lecturer to Manitoba Trial Lawyer Association on Polygraph use 

1994 Guest Lecturer to Western Canadian Police Womens Assoc, on Interrogation & 
Interview techniques 

Given evidence in over 300 cases. All levels of the Judicial system from Traffic Court, 
Provincial Judges Court & Court of Queens Bench. Considered expert witness on Polygraph. 
Conducted over 700 Polygraph examinations. Numerous In Service Courses with W.C.P. 



STATUTORY DECLARATION of Julia Balik and Edward Balik 

Made this £0 day of June, A.D., 1996 



Julia Balik 
Edward Baiik 
63 Inman Avenue 
Winnipeg, MB. R2M0R7 



Tel: 204-256-5905 



STATUTORY DECLARATION 

We, Julia Balik and Edward Balik residing at the City of Winnipeg, in the Province of 
Manitoba, do solemnly declare: 

1. That in 1993, our daughter Tatiana Balik at the age of twenty(20) years, commenced a 
course of therapeutic counseling in the City of Winnipeg under the care of a therapist, 
giving her name as Morgana Lafaye employed or associated with the Serene Counseling 
Service, and 

2. That during our daughter's course of therapeutic counseling, she(Tatiana) developed 
false memories of having been sexually molested by her father Edward Balik in her 
childhood, wherein she(Tatiana) began to recall false memories of events that never 
happened, and 

3. That in 1995, we received a threatening letter from a City of Winnipeg Lawyer, one 
Albert H. Redekopp representing our daughter(Tatiana Balik), wherein false allegations 
of childhood sexual abuse are made against us, and 

4. That we believe our daughter has and is continuing to receive fraudulent false memory 
recovery therapy, a form of fraudulent therapy that we believe was first introduced into 
Manitoba by Dr. Colin A. Ross in 1985. 

5. That this fraudulent false memory recovery therapy has devastated our family and we 
will seek whatever relief that is available, and 

That we make this solemn declaration believing it to be true, and knowing that it is of the 
same force and effect as if made under oath. 



Declared before me at the Declarants: 

City of Winnipeg, in the Province ///"/? ®/ 

of Manitoba, this 2 day J/sOXt^ /&&*6zsf 

of L^^a ,Ad>1996. ^ha Balik/^ 



Ge^ge Bergen ^ y^> ^^ > ^ ,y ^^ //^ /\ff 

Commissioner of Oath in and for the Edward Baiik~" 

Province of Manitoba. My Commission 
expires on March 26, 1998. 




STATUTORY DECLARATION of Lawrence Kyle 

Made this / % ~~ day of June,A.D„ 1996 



Mr. Lawrence Kyle 
6 Fleury Place 
Winnipeg, MB. R2J2J1 

Tel: 204-257-1939 or 
204-252-1939 



STATUTORY DECLARATION 

I, Lawrence Kyle at the City of Winnipeg in the province of Manitoba do hereby solemnly declare: 

.) That, in 1989 , i was approached by Cpl. Duggan, of the Yorkton, Saskatchewan detachment of the RCMP. 
He informed me that, my son Kevin Patrick Kyle, after months of treatment in the St. Norbert youth centre (now 
known as St. Norbert Foundation, X-Kalay Industries, --name changed after controversy over treatment 
techniques), made the following accusations. Namely, that I had sexually abused him, and that he had seen me 
do the same to his younger brother and sister. These accusations are false and no charges were laid. 

2} That, in 1993 my son Kevin Patrick Kyle at the city of Winnipeg was admitted to the St. Boniface General 
Hosptal psychiatric ward and, was diagnosed as having a condition known as multiple personality disorder 
(MPD). 

3) That, on June 8, 1994, 1 was confronted at my place of employment, by officers Gregg Burnett and Jim Bell 
of the City of Winnipeg Police Department and was threatened by them with criminal charges relating to 
accusations made by my son Kevin Patrick Kyle. Namely, that from November 1, 1993 to January 1994, 1 had 
often taken him to gay bars and then taken him to my home and sexually abused him. These accusations are 
also false and no charges actually laid. 

4} That, i believe that my son Kevin Patrick Kyle received fraudulent memory recovery /MPD diagnostic therapy 
at the St. Boniface Hospital in 1 993-94 and probably in St. Norbert as early as 1 987. I am given to understand 
uch therapy was introduced in Winnipeg in 1985 by Dr. Colin A. Ross, who was employed at the St. Boniface 
Hospital and the University of Manitoba from 1985 to 1991 and, that such therapy continues after his 

departure. 

5) That I make this solemn declaration conscientiously believing it to be true, and knowing it is of the same 
force and effect as if made under oath. 



Declared before me at the Declarant: 

City of Winnipeg, in the Province \j? 

of Manitoba, this /tf ^ day ^/frt/ZZiLCtS 

Lawrence Kyle 





George Bergen 



Commissioner of Oaths in and for the Province 
of Manitoba. My Commission expires 
on March 26,1998. 



STATUTORY DECLARATION of Niall Rennie 

Made this P Jb day of June, 1996. 



Niall Rennie 
39 InksterBlvd 
Winnipeg, MB. R2W 0J3 

Tel: 204-586-2791 



STATUTORY DECLARATION . 

[, Niall Authur Remtic, a resident of the City of Winnipeg, in the Province of 
Manitoba, do solemnly declare: 

1. That in 1992, my then spouse Corina Rennie(nee Perchotte) and myself(Niall Authur Rennie) 
commenced a course of therapeutic marriage counseling under the care of one Keith McKmnon 
employed by the Civil Service Commission in the Employee Assistance Program, and 

2. That in the first few counseling sessions with Keith Mckinnon, he in my 

(Niall Authur Rennie's) presence indicated to my then spouse that she(Corina Rennie), 
without herself(Corina Rennie) being fully aware of it, had made numerous references 
to sexual abuse issues, and 

3. That prior to the marriage counseling sessions with Keith Mckinnon in 1992, my then 
spouse(Corina Rennie) had never expressed or recounted to me(Niail Authur Rennie) 

memories of sexual abuse in her childhood, and 

4. That in or about the third counseling session, Keith Mckinnon, in my presence, suggested to 
my then spouse(Corina Rennie) that he(Mckinnon) would pursue a course of memory recovery 
therapy, if Corina decided that this was the avenue that she(Corina) wanted to pursue, and 

5. That after the first few marriage counseling sessions attended by both myself(Niall Authur 
Rennie) and my then spouse(Corina Rennie), Keith McKinnon then proceeded to meet privately 
with Corina Rennie for the purpose of therapeutic counseling to investigate the possibilities of 
recovering past memories of sexual abuse that may be causing her(Corina Rennie) emotional 
difficulties, and 

6. That after many months of searching for sexual abuse memories in her childhood and reading 
literature suggested to her(Corina) by therapist Keith Mckinnon, Corina began to get false 
memory 'flashbacks' of having been sexually abused by her father, John Yvon Perchotte, and 



7. That in 1993, Corina Retime believed that she was in love with the Civil Service Commission 
counselor Keith McKimion, and she believed that Keith Mckinnon would leave his(McKinnon , s) 
wife t o-live with hcrf Corina Ronn?^ , and 

8. That by 1994 Corina Rennie falsely believed that all of her emotional problems where the 
result of having been sexually abused by her father; false sexual abuse memories of events that 
never happened; false memories implanted in therapy sessions by Keith McKinnon, and 

9. That in 1994, Corina Rennie commenced a course of therapeutic counseling under the care or 
a memory recovery specialist one Judy Hill, at the City of Winnipeg in the Province of 
Manitoba, and 

10. That in June 1995, Corina Rennie confronted her father and falsely accused him(Corina's 
father) of having sodomized her and sexually abused her(Corina) during her Childhood, and 

1 1. That the fraudulent false memory recovery therapy introduced into Manitoba by Dr. Colin A. 
Ross in 1985, and which therapy was practiced by Keith McKinnon and Judy Hill, has 
devastated our family relationships, and has left Corina Rennie, I believe, in a condition where 
she is unable to differentiate between imaginary suggestions made to her(Corina) and real 
events, and I will seek whatever relief that is available, and 

That I make this solemn declaration conscientiously believing it to be true, and knowing that it is 
of the same force and effect as if made under oath. 



Declared before me at the 

City of Winnipeg, in the Province Declarant: 

Manitoba, this %£ day . ^Yfif~) 

_/A.D., 1996--J hMsS^L , 

&. I -< *_**>-— Niall Authur Rennie 



of 
Geor 





Commissioner of Oaths in and for the 
Province of Manitoba, My Commission 
expires on March 26, 1998. 



STATUTORY DECARATION of Gail Laverne Dueck and Wilhelm Dueck 

Made this l<6 day of May, 1996 



Gail & Wilhelm Dueck 
Box 128 
R.R. 5 

Winnipeg, MB. R2C 222 

Tel: 204- 222- 0955 



STATUTORY DECLARATION 

We, Gail Laverne Dueck and Wilhclm Ducck, married and residing at the City of 
Winnipeg, in the Province of Manitoba, do solemnly declare: 

1. That in 1991, our daughter Sherri Lea Dueck nineteen( 19) years of age, commenced a 
course of counseling under the care of therapist and Christian counselor Jackie Reimer 
who we believe was associated with or employed by the Winnipeg Christian Counseling 
Group, an agency of the Grant Memorial Baptist Church. 

2. That by 1992, the Christian counselor Jackie Reimer, through a process of suggestion 
and memory recovery therapy, induced or implanted Sherri's mind with false memories 
that led her(Sherri Lea Dueck) to believe that she(Sherri Lea Dueck) had been the victim 
of sexual abuse by Sherri Lea Dueck's parents during her childhood years and that this 
was the devil's work. 

3. That Timothy and Corrine Plett, of the City of Winnipeg, being managers of the 
Cedarwood Camp, a Christian summer youth camp, employed Sherri Lea Dueck in 1991, 
and that Timothy and Corrine Plett since 1991 have imparted to Sherri and others, that 
they(Timothy and Corrine Plett) believe the false memories of childhood sexual abuse 
induced or implanted by therapist Jackie Reimer. 

4. That therapist and counselor Jackie Reimer is currently in 1996, associated with and 
practicing therapy at the Crisis Pregnancy Centre of Winnipeg, having offices at 650 
Broadway, in the City of Winnipeg. 

5. That we have been threatened with legal action against us for sexually abusing our 
daughter Sherri in her childhood, on the basis of the false memories that were generated 
in therapeutic counseling by Jackie Reimer. 



6. That Sherri Lea Dueck attended nurse training school at the St. Boniface Hospital 
during the winter of 1991/92, and that she dropped out of nursing school in the spring of 
1992. 

7. That Sherri married Allan Maiazdrewich on October, 4, 1992 in the City of Winnipeg. 

8. That in April, 1996, our now married daughter, Sherri Lea Malazdrewich(nee Dueck) 
commenced another counseling regime under Christian counselor Nancy Gemey, from 
New Direction for Life Ministries, and who(Nancy Gemey) is continuing a similar false 
memory recovery counseling therapy commenced by Jackie Reimer in 1991. Nancy 
Gemey's mailing address is New Directions for Life Ministries, P.O. Box 1492 
Winnipeg, Manitoba. 

9. That the fraudulent and false memory recovery therapy, first introduced into Manitoba 
by Dr. Colin A. Ross in 1985, and which is 

practiced and/or encouraged by Jackie Reimer, Nancy Gemey, Tim and Conine Plett in 
the counseling of our daughter Sherri Lea Dueck has devastated our immediate and 
extended family and we will seek whatever relief that is available. 

That we make this solemn declaration conscientiously believing it to be true, and 
knowing that it is of the same force and effect as if made under oath. 



Declared before me at the 

City of Winnipeg, in the Province 

Manitoba, this 



Declarants: 



of 



, 1996. 



7^; 

George Bergen ^S^vry ^ ^^/y^ 

Commissioner of Oaths in and for the 
Province of Manitoba. My Commission 
expires March 26, 1998. 



Gail Laverne Dueck 
Wilhelm Dueck / 



' ' Wilhelm 




STATUTORY DECLARATION OF ROMA ELIZABETH HART 

Declared this 3 I Day of May, 1996 



Roma Elisabeth Hart 
27-937 Greencrest Avenue 
Winnipeg, MB. R3T 4S8 

Telephone: 204-275-5723 



STATUTORY DECLARATION 

I, Roma Elizabeth Hart, of the city of Winnipeg in the Province of Manitoba, do 
solemnly declare: 

1. That in 1984, 1 worked for the Provincial Government as a project manager on the 
Cultural Integration of Refugee Children Program, while attending progressive part-time 
studies at the University of Manitoba in the Faculty of Education. 



2. That from 1981 to 1989, 1 worked at the Black Hole Theatre in the City of 
Winnipeg, being promoted first to house manager and then to stage manager, while 
attending progressive part-time studies at the University of Manitoba Faculty of 
Education. 



3. That in 1985, 1 won the University of Manitoba, Faculty of Arts theatre competition 
award for overall excellence in directing. 



4. That in October, 1986, 1 developed minor stress symptoms from working, attending 
the University of Manitoba and being a single parent, and I, therefore, went to the 
University's Student Psych Services office on campus and requested that medical 
authorization be approved in filing my unemployment insurance claim form. 



5. That in October 1 986, Lynne Ryan, the intake worker at the University of Manitoba, 
anxiety disorders clinic, directed me to Dr. Colin A. Ross, who she (Ryan) assured me 
would assist me in filling out my unemployment insurance claim form. 



/ /? 



6. That in October, 1986, I met with Dr. Colin A. Ross, mid I requested that he assist me 
in filling- out my unemployment insurance claim form, whereupon Dr. Ross interviewed 
me, before he would deal with my request to have him(Ross) authorize my 
unemployment insurance claim form. 



7. That in October, 1986, at my first interview with Dr. Ross, after approximately one- 
half hour, he(Dr. Ross) held out his hand and said, "welcome to MPD(multiple 
personality disorder) therapy", while shaking my hand. 



8. That beginning in October, 1986, Dr. Colin A. Ross placed me on his MPD therapy 
treatment program, which consisted of high dosages of medication, hypnotherapy, and a 
constant search for "alters personalities" and childhood sexual and satanic ritual cult 
abuse memories that he suggested had occurred in my family. 



9. That within the first six months of therapy under Dr. Colin A. Ross, he(Ross) had me 
believing that I had repressed a memory of having been impregnated and given birth to a 
child from an alien being, which terrified and upset me greatly. 



10. That during 1987 and 1988, under Dr. Colin Ross's hypnotherapy, drugs and 
suggestions, I came to believe that I had as a child been subjected to incest by my entire 
family, and that I had been a childhood victim of an endless stream of satanic cult abuse, 
and that my family had been part of a satanic cult. 



/ /? 



11. That due to the large dosages of addictive medication and therapy I became totally 
dependent on Dr. Colin Ross, and because of the therapy, I was no longer able to care for 
my young daughter, as I needed periodic hospitalization in order to cope with the 
debilitating affects of the medication and the recovered satanic ritual abuse memories. 

12. That from October, 19S6, to November, 1991, Dr. Colin A. Ross, through his(Ross's) 
medication and hypnotherapy, had complete control of my life, and he(Ross) could illicit 
"alter personalities" and satanic ritual cult abuse memories from me at will by suggesting 
that he would give me a sodium amytal needle. Dr. Colin A. Ross knew I feared needles, 
and I always wanted to please Dr. Ross by saying whatever it took to make him feel 
happy, just like his other MPD patients. 

13. That during the times I was hospitalized, I learned that all of Dr. Ross's MPD patients 
became suicidal and I was no exception. 

14. That while under Dr. Ross's care from October, 1986, to November, 1991, 1 
attempted suicides many times. 

15. That Wanda Davenport and her best friend Terry, both treated by Dr. Ross, 
committed suicide in or about 1989, because they could no longer bear the torment of 
remembering horrendous family incest and sexual abuse memories that Dr. Colin Ross 
had induced in their minds and which they came to believe as being a real and part of 
their childhood. 

16. That after an unsuccessful suicide attempt by one of Ross's MPD patients, he(Ross) 
would quiz them about whether they had seen any white Sights or had other near death 
experiences. 



[7. At the beginning of my treatment program, in 1986, Dr. Ross would regularly hug 
and stoke his patients, rub their backs and arms, and put his hands on their legs; until 
there was an uproar about it and he then stopped this form of 'treatment'. 

1 S. When Dr. Ross felt that one of his more pretty MPD patients was ready to have her 
"alter" personalities integrated, he(Ross) would take them out to Chi Chi's for an 
"integration dinner celebration". 

19. That from October, 1936, to November, 1991, Dr. Colin Ross would regularly 
prescribe large overdoses of addictive medication, that left me with many fainting spells, 
hallucinations, dizziness, nightmares, a staggering gait, fatigue, and it often changed my 
easy going friendly character to one of a drug induced hostility and rage. 

20. That between 1989 and 1991, on at least two occasions, Dr. Ross suggested to me that 
I should go ahead and commit suicide and kill my parents. Dr. Ross would telephone me 
late at night and suggest this to me. 

21. That between December, 5, 1989, and January 9, 1990, Dr. Colin Ross, admitted me 
to the St. Boniface Hospital and placed me on massive overdoses of triazolam of up to 51 
mg per day, or 100 times the maximum allowed dosage set by the manufacturer. This is a 
restricted drug and is reported to cause death in overdosages, (see Appendix "A") 

22. That on June 1 1 and again on June 28, 1990, as an outpatient, Dr. Ross prescribed and 
directed me to take twenty(20) times the maximum per day limit of triazolam set out by 
the manufacturer, a restricted hypnotic and addictive drug, which overdose can cause 
death. (see Appendix A) <ry^' 

23. That on June 4 and again on June 12, 1990, as an outpatient, Dr. Ross prescribed and 
directed me to take two(2) times the maximum per day dosage limit of diazepam set out 
by the manufacturer, (see Appendix A) This is also a restricted drug. ^ A 



24. That while I was under Dr. Ross's care, he would have me take triazolam and/or 
diazepam plus cimetidine, even though both triazolam and diazepam are coatraindicated 
with cimetidine according to Pharmaceutical Manuals. 

25. That during the summer of 1990, Dr. Cotin Ross arranged to have Winnipeg Police 
Officer, Russ Heslop interview me and other MPD patients about the satanic ritual cult 
abuse memories induced by Dr. Ross in therapy sessions. 

26. That on at least ten occasions Dr. Ross provided me with addictive drugs in a brown 
paper envelope across his desk, to avoid leaving a paper trail in dispensing restricted 
drugs. 

27 That due to Dr. Colin Ross's destructive false memory recovery/MPD diagnostic 
therapy, my career in teaching has been destroyed, and I have been unable to find any 
other employment. 

And that I make this solemn declaration conscientiously believing it to be true, and 
knowing that it is of the same force and effect as if made under oath. 

Declared before me at the City of 

Winnipeg, in the province of 

Manitoba, this 3/ th, Day of Declarant: 

May, AD. 1996. AjE^kA 

George Bergen X^y?/ £W„„ Ro™a Elizabeth Hart 



Commissioner of Oaths in and for the 
Province of Manitoba. My Commission 
expires March 26, 1998. 



(^qut^M^ ft 



ST. BONIFACE GENERAL HOSPITAL 
DISCHARGE SUMMARY . 

(To be completed on Ditclnrgc or Transfer of Picieni) 



ATTENDING PHYSICIAN: Dr. C Ross 

PATIENT'S NAME: Elizabeth Hart 

DATE OF ADMISSION: Dec. 5/89 

COPIES TO: Charc/Dr. C. Ross 




UNIT No: 454438 

D.O.B. \ Feb. 4/59 

DATE OF DISCHARGE: Jan. 9/90 



Elizabeth Hart is a 30-year-old, single, unemployed woman 
townhouse on Welfare . 



living by herself in a 



ENTRANCE COMPLAINT: 

She was admitted on an elective basis after considerable discussion and planning for 
treatment of her multiple personality disorder. 

HISTORY OF PRESENT ILLNESS: 

She has been on treatment for a multiple personality disorder for three years and has 
had previous admissions to M3 which are documented in discharge summaries. Over the 
past year she has been unable to make any sustained progress in outpatient j*«apy. 
She attributes this to her ongoing traumatic life situation. She is stressed by the 
difficulties she is having attempting to reestablish a relationship with her <^ghter 
who has been in foster care since 1987. She says that there is no place ior her to 
live which is ndt producing severe chronic trauma. She says that when she tries to 
stay at her own townhouse, that she is subject to harassment by members or a satanic 
cult in which she has been involved. She claims that they bother her in a variety or 
ways including breaking into her house and spreading blood around the house. She 
stated that she has been directly involved in three ritual sacrifices or human beings 
in the summer of 1989. She identified these individuals as j ohns of hers She also 
says that she murdered another person in August, 1989 and that cult members helped her 
dispose of the body. These claims were discussed at length with her and 
Constable Russ Keslop of the Winnipeg City Police who pursued a number of lines at 
investigation based on statements she made, but nothing positive turned up. There is 
no conclusive proof that this satanic cult exists or that any of these murders 
actually took place. The third source of stress that she cited was her relationship 
with her boyfriend who is in his 50's and lives in an apartment downtown She 
characterizes him as sexually abusive, self-interested and interested in her only as a 
sexual object. She claims to remain in this relationship because there are no 
alternatives in her life and because a relationship with him might be useful if he 
takes Child & Family Services to court concerning her daughter. During the past year 
he Lf had severe symptoms of multiple personality disorder ^^^^^ 
symptoms, depression, an eating disorder, episodes of amnesia, uncontrolled s-i.chmg 



ninrii I »n^r o! 



iMM/S 



Page 2 

Re ; Elizabeth Hare 




PAST PSYCHIATRIC HISTORY: , _, -y^'j 



,1 -w^ 



,^r""^' 



See previous discharge summaries. / .' 

MEDICAL & SURGICAL HISTORY: <iO 

At Che Lime of admission her medications consisted of diazepam 20 mg q.i.d. 
PERSONAL & SOCIAL HISTORY: a ( <f ^/Z^^/^l 

trauma including physical and sexual a^se _ ela « d mur ders by her father. She 
involvement in eule activity uncil recently. 

LABORATORY INVESTIGATION'S: 

, lnH ,, calcium and glucose were normal. Urea and creatinine 
Sodium, potassium, chloride, calcium ana S^ albumin was 33, normal is 

were normal. Total protein was low at 5. normal is bU au hemo£lo bin was 112 and 
33-45. There was evidence of a mild macrocytic anemia. her hemoglobin 
mean cell hemoglobin was elevated at 31.5. 

PHYSICAL EXAMINATION: 

No abnormalities were noted on physical examination. 

KFNTAL STATUS EXAMINATION: 



was 



i - j „-iaT-- udl-zroomed woman who 
A t the time of admission she was an orien a, aler^ well gr ^ ^ 

appropriately dressed and cooperative ^™™\ W s j£ Ration or psychomotor 
rhythm and tone. There was no evidence or se«t 6 chere uas a 
retardation. Her thought processes were rational and intact, except 



Page 3 

p.e: Elisabeth Hare 

B//45 ^ 38 • sacrifices were real, 

, ■ ~f involvement and sacanxc sa anE rv No 

, . h ,, her claims of W VOiVcm . _ nd predominantly angty. i« 

question as to whe.he. he. broad in ran&e *^ d ? r inCac c. She had 

'fabrications or delusion s He ; «o Her concentration was i _ she 

KroSS cognitive impairment wa, s Her judgement appearea homicid al and 

L sl8h , i«. £.»--' &.?&«. ^ f ^r« x""."." « ^°- 



KultipU personality disorder. ^ a/V!^ 



X 



choice for inpatient 



i£=£±iii^-=- — / l . . choice for mpa^*"- 

X *,- v, is her benzodiazepine or cno x 

she vas ^jr^ J^^t « control 

and suppress V J P °*Vl- Y s"« «« Hso ^VT^sur »0 i t. i. *• which she 
agitation and ^" bl ^V y ' 6t ly. This consisted o : Ensur >™ J of clari fying the 
disorder and does "V ^n Some work was done with her rn « integra ted in 
took throughout the admission So ^ ^ d P«»°^£J% eXU *l assault by a 
state of her P'" ™ 1 ^*^" was the victim of an ^^f assault. He had no 
December. On December ^ *e about ih hours prior «th- vlolenC e or assault 
copatient. He had been ^dm ^e abuse of any perso ns was kissLn g 

devious history of sexual assa uV c push(jd har to the 8^ ^ ^ caused 

presence. ^ tendency to ;">sry 

ris is a difficult »«"« ^"'^ profe'eci" o£ her »»«.«J»« °*^ g 

tti, has been "*»"" t l ^ l « h.« behavior S redu a lly ^»»°/^ 1: , although It «. 

*' e ^*;.°4lS" »"«•* « "^ „ r a e o f"tL ad» salon ■- ™ T^'" or "o 

seem to be airecL-j-jr Towards the end or trie <* ■ , t ^ e day p-iv- 

exacerbated by the ""^ *£" sta ff in a variety or "£*£* off breakln g it and 
Tanipulative She v tnre ening^ ^ ^^ , , cklace^ ^ 

discharge she spit ma n earrings out. n B . eC ^ S relaT:i onship to staff, 
threatened to pull th- nu sCand sh e took ir re - AnoCher reason .or 

beha vior and because o *. £ chBr ^ eEapy so sh o was xschar^ ^ ^ una cceptaole 
ira p OS sible to <="*? ° / clear me ssage to her ^at ^ ^ possibility 

discharge was to delive a ^^ co h r that ^^ she lS to 

* nd ViU "^ he fu u ; de ? endin S on ^ behav, ; ^ ^ boy£riend uas sexuaUy 
admission in the tut ' Although she state 
followed in outpatient follow ? u 



page l* 

R e: Elizabeth Hart 



B// .. her out on weekend passes 

„ of he, and ch.r««ri£ | ~ « ^ ti ^ ^^^ 

wich hi,, which were in »« ^^nd pas* during a^^ a, ,he tiae of 
nurS es on return from he las ^ ^ ^ doses of «i«« ^ tha 

bovfriend were engaged. Because and this was to be a ■ V q£ 

di.char... she was conned « ^ap ^ ^ f disch ar je wa ^^S ^ 

pna^acy -e^day a a ^ ^ by 20 m& pe r day which - J£ ^ ^ ^ 
rb7"^ «* ^roV/Vo ^inr^e/ra^ower dose of dU.. ? «. She „ 

s^ s :d-rou^rfoLow. P hy D r. R o S5 . 



Dr. C. Ross 



/sp 

90/01/11 
90/01/12 



QsflsfL2^~J-*^ fl 



4. 



:;£HT HART, ELIZABETH 



LA/IG E FLANS FSA 



feSSSSSrT||5 r ? , !|tii a s TABLETS D«LY 

io.dir a 
3.05W API OIAZtPAH ..--.---■-■■■---■■ii.oii; 3— - - -■ - 

n'M r.r-^^^T STs 10 3 FORM TAS 

■•;'.i.un fji >-ro*M fli A li.oEdSo a.jJ iJ.XtrtMl J.. lVLuLu x 

,wt n n*/\ opj I'M HI 5 Ifi^O. C.JJ Ij,'v.u.ii,;i!I 



, - ... ■.-,,-, a cry 8^ i.U/V V 14. DOCTOR R OSS , COLI N 

V.WEWOiOl ''7.8ELLP3A ' IKIT SH S27-291? WTACffi 



REFILLS' ■!■ LAST--?00:i:l-—FF.E? ■■-.' 






UA7IEW HART, ELUAGETr 



LAItfl E FLAII3 F9A 



KKI 



r ■ _ ( - ■' ■", 

ui ley- 



W xmt-.f ««■'"">» Mftj.-Hi 9.DIK ■1--TAKE---40 ■-•TAQLETS-DniL i-m u 



2, DRUG APO -TSIAZ0 



lC.'oiR iSE-TAKEN'- IN DIVIDED DOSES 
U.QIit 3 



;:;■! 30S57I S.K ...0.25H5.- ,F»ft.,,T™ ., „„ r , T 5 -- .•■«■"* 

IH^TT^ 6 ^^ Cj-g '"■' * NSCEV 30 .'23 lTcM. fl":..D AY .IN 

lw. .1-.403- r« -v Cut u* 0iC0 VALG/G!< JlJN , 

„ „ u ™™ j .-v__i ££> 3.«'v V U.-DKTGS ROSS, CGLIN * ■■ 

^■^ n -'K1 ^VsiLLPSA ' IH-fSh 237-251? 40? TACHE " . 

l.llhiC 7OO0II , .BILL, rjrt iii; 1 -- n ,,,. ^„-_. 1r ,-< 

_, — ,.,-.■ r . ■, tr- AMI"? ??rv " tiLjt.' Ill = -' --"- 



TER- 



r.crlLi.1 



i,3T ?00£27 FaE 



PAGE 1234 



5-?3S CfiF.RISAfi PLACE SIh-12-SC- 

•:;d safety ■vialesusk sbs-shith ssof s. sib oh. 



::,CF^ il?3 DIAZEFAH 
D!;l ^05337 STR 
EE-I-mFG OIAZEPftH - 



7.DIR 1 TAKE 12 TABLETS (120fiG) 

-1G.DIR2DAILV-IN DIVIDED -DOSES. 

11.DIR3 ■ ■ ■ 

10H3 FOHH TA3 

AFX I2.GSGSS 2. Si 13.REJW - Ji-i?^ 1 .._ 






Li\ X I K I C_ t\ v f-i <•— O 



PATIENT 0.00 
84 5 . '-7V 'J lo . OCCjTC?. _R_0 S S , C O L I N 



** 0-i" I'I"?t £ CTV 

A.G;"c-9wna---?-.oiu. ?c; ■ r -iMT-!iu-- S: ,7- e ,i> X'n T - -■- ^C 

REFILLS LAST 700712 FStS -. ■ , ALsS fi . ... -2«b 



FACE i.237 



i.MTIEHT-KART/ELI^BETK 
:'-?23 MF.SIGmII FLAlE doi-id'-J 



■-LAK 



., ; :ro T-: " ' 



V FT 1 ! < 



?rSiti KS.Si:i7H m s.sig.qe take .. 5 o. tablets, daily fi 



u 






<, -^ m %r, id. u «uc3 -^r.zr-n)7i?E J ?e)Tr = *-i"- -fccscrx"^ 



1 rr!'-" j y 



cui./V, 1 L.-.' 






PATIENT ■ 0.00 



~~-r s r:n n :rr~ 



f> 



2. ..■;!! 47??i'3 4.3TY 2S0 S.'-VJ U ii.CDCTCIl ROSS, COLIN 

o.DATE ?CW23--7.3ILL Fin " -INiT Sri S37-S7L? 407 TAl'HE 

•EFiltS i LAST ?00,W FSEI 3 ALSO FK 237-2335 



&ff 



.&~^^-~tf(-*4^?^— I 1 



REFERENCE 

PEMBINA TRAIL 



Mi', 




Compendium 
of Pharmaceuticals 
and Specialties 

Thirty-First Edition 1996 




The Canadian Reference 
for Health Professionals 



596 • HALC 
HAbilroi [Cont'd) 



Ttii! .liiuiiOJiion ol swcr.it Hahilrol Systems simultaneously, 
cuulit' result "i serious overdosage. The eltects ol chawing 
,iih1 sw.illnwiiui Habitroi arc unknown. 
Chronic Toxic Eltects; No experience has been obtained with 
S(-|-nitt)tiiie treatment longer ifi.in 3 months duration 
Manatiomem ol Excessive Tooic.il Exposure: II the daiient 
siww:; smns ol overdosage. Hahilrol Should be removed 
innni!di.in!iv The skin may be washed wit" water only, as 
soap may facilitate absorption Owing to J depot ol nicotine 
lit the skin, delivery o( nicotine to the bloodstream will con- 
tinue lor several hours afterward. 

M.inaijnmenl Ol Nicoltno Poisoning: In cases ol severe poi- 
soning, Ihe following measures are recommended: suaoomve 
measures lor sei;ure conlrol. warming the body to normal 
temperature, amlicial respiration m the case ol respiratory 
i.nuire, atropine lor excessive bronchial sccrclions and vnj- 
orous lluid support tor pronounced hypotension or cardiovas- 
cular collapse, 

Oc-sage; When starting treatment with S(-)-nicoline. trie 
patient should sioo smoking comolelcly. 

One Habitroi system should he applied daily and left on Ihe 
skin lor 2« hours 

if me patient has been unable to maintain or otherwise 
re-establish initial abstinence with the aid ol Habitroi after 
1 month, the treatment should be discontinued. 

Prolonged continuous use ol Habitroi should not exceed 
3 months 

Treatment is divided into 3 components: selection and evalua- 
tion of an initial dosage strength, a maintenance phase and a 
- weaning phase. Treatment may be completed tn as little as 
7 weens, but more typically lasts 9 to a maximum of 12 weeks. 
The dosaoe strengths employed, and the duration of use of 
each, deoend upon the individual patient's response. Tobacco 
withdrawal must be accompanied by behavioral suppon at 
all limes. 

Selection and Evaluation: Treatment is initiated with Habitroi 
21 mg/day or H mg/day, depending on the number of ciga- 
rettes smoked per day. Habitroi 21 mg/tlay is usually recom- 
mended lor smokers with a consumption ot more than 

20 cigarettes a day. Habitroi 14 mg/day is usually sufficient 
for smokers with a consumption of up to 20 cigarertes daily. 
The dosage strength may be adjusted early in the maintenance j 
phase in response to either the appearance ot sioe effects or j 
difficulty in maintaining abstinence. 

Maintenance: The intial dosage strength selected should gen- 
erally be worn for 3 to 4 weeks, but this pence may be 
exter ded. Consideration may be given to an extension ol this 
period to 6 to 8 weeks if Habitroi if mg/day was selected as 
me initial dosage strength. 
Weaning: The goal ol a stepwise reduction trom Habitroi 

21 mg/day to the lowest dosage strength is accomplished by 
an intermediate step employing Habitroi 14 mg/day. typically 
worn for 3 to t weeks, whereas Habitroi 7 mg/day is employed 
directly after maintenance on Habitroi 14 mg/day. Haoitroi 
7 mg/oay, designed to reduce nicotine suostilution toward tne 
end of therapy and consolidate abstinence, shouio typically 
be worn (or 3 fo 4 weeks. The weaning phase may be com- 
pressed if the maintenance phase has been extencec. 

After completing treatment with Habitroi it is advisable for 
psychological/behavioral therapy to be continued. 

Wo experience is available on treatment with S(-)-nicotine in 
smokers below the age ol 13 and is limned in aces 65 years 
and above (see Warnings). 

Administration: To avoid evaporative loss ol nicotine, and as 
a matter ol safety with regard to accidental exposure ol chil- 
dren and pets, me system Should be applied promptly after 
its removal from the protective pouch. Alter removing the 
release liner (lirst the smaller strip and then the larger portion), 
the Haoitroi system should be applied to a clean, oil-free, non- 
hairy, dry, ini3c! area of skin on Ihe trunk, or the upper outer 
arm, A different site ol application should be cnosen eac.n 
day. and no site should be re-used within 1 week. The patient 
should be advised that the system not be worn lor longer than 
24 hours, and to dispose ol used systems out of the reach of 
children 3nd pets. For detailed instructions see Information lor 
tne Patient. 

Hole: Dosage adjustment cannol be achieved by cutting a 
transdermal system. This will cause the nicotine to evaporate 
rapidly, and render the pieces ineffective. 
Safety Nate Concerning Children: Nicotine is a highly to/ic 
substance. Doses ol ivcoiine which are tolerate; ay adult; 



durum tnuiineni with H.lnilroi can produce seven! svmoionis 
ot noisiiiitiw m small children isnn W.uniriijst Even altnr use, 
H.ilinml contains more than halt ol it:', initial iiiciiline r.onient 
Therelore pniienls rnusi be cautioned that new ami used sys- 
tem:; musl not he handled casually or letl where they mav be 
misused (by aotiiicalmnl or nnieslnd. 

Similarly, care must aisn be taken when riisoosmo of used 
systems (lor detailed instruclion", see Iniorniaiion lor the 
Patientl 

Inlofm-ilinn lor Ihe Patient: Sen Blue Sectinn-lnlormatinn 
lor tne I'.iiinni ■'Habitroi' 
Supplied; See Taoie III 



Table 111— Hahilrol 
Dosage Forms 



Habitroi Habitroi Habitroi 
7 me/day 14 mo/day 21 niqjday 



Average dose (mat of 
S(-l-nicotine delivered 
in vivo during 2-1 hours 
Content ol S(-)-niCOtine 
(mg) 

Drug releasing area 
<cm ; ) 

Printed code 
(on backing luml 



17.5 

10 

ewe 



35 
20 
FEF 



2! 

52.5 
30 
EME 



The total amount of S(-)-nicoline in the reservoir is needed 
to maintain the delivery pattern as reouireo while the system 
is being worn. 

Since the amount of Sl-i-nicotine released from Habitroi 
per cm-' is cpnstant, the cose administered is determined 
solely by the size of the contact area ol the system. 

Store below 25°C, Do not store unpoucned. Apply immedi- 
ately upon removal from tne protective poucn. 

(Shown in Product Recognition Section) 
Reviewed J9S~ 



HALC1NON1DE 12 

Ge neral Monograph, CPhA 
see Corticosteroids: Topical 



HALCION* 

Upjohn 
Triazolam 



E 



Hypnotic 

Pharmacology: Triazolam is a benzodiazepine with a very 
short elimination half-life (about 3 hours). 

In sleep laboratory stuoies in man of 1 to 21 days duraiinn, 
triazolam signilontly reduced sleep latency, increased dura- 
tion ol sleep and decreased the number of nocturnal awaken- 
ings However, after 2 weeks of consecutive nightly 
administration, the drug's effect on total wake time is 
decreased and the values recorded m the last third ol me 
night approach baseline levels. On the firs: and/or second 
night after drug discontinuance (first or second post-drug 
night) total ttrnc asleep, and percentage of time spent 
sleeping frepuently were signilicantly decreased, and sleep 
latency significantly increased when compared to baseline 
(predrug) mgnts. This effect is often called "rebound 
insomnia. , . ,„, 

Thf duration ol hypnotic eflect and the profile of unwarned 
effects may be influenced ;v the alpna (distribution) and beta 
(elimination) hall-lives of tne administered drug and any active 
metacolnes lormed. When hall-lives are long, ihe drug or 
metabolites may accumulate during periods of nightly adminis- 
tration and be associated with impairments ol cognitive and 
motor perlormance during waking hours, if halt-lives are 
short Ihe drug and metaooiites will be cleared before the next 
dose 'is ingested, and carry-over eilecis related to sedation or 
CNS depression should be minimal or assent. However, during 
nightly use and lor an emended period, pharmacodynamic 
tolerance or adaptation to some effects of benzodiazepine hyp- 
nptics may develop. II the drug has a very short elimination 
hall-file it is possible thai a relative deficiency (re., in relation 
to thr. receptor site) may occur at seme point in the misr/al 
between each night's u:e. This seauence ol events may 
accouni lor two clinical findings reponed to occur alter several 



W! , 1!K ,; ,ii iiwhliv use ni i.iuiihv eiiiiiiii.itnit bciUMi.venm,, „ 
nunc:'- H "icrt'.isei! w.iki'iiiliiess duiing llu: Ms; Hut,] n| ^ 
ttmiii' .mil 21 thi' .iiiDit.ii -inci: "I increased o.iviun,; l1m|(M J 
(st:<* \V.i"iinii:'-l 

When sed.iliini and psvclioriiiiwr performance wen; ,- 0m 
l)-iri>ii in he.Hlhv niiterlv and vniino subjects, hi resonnse i 
O ami -> m« dose? ol truzof.nn. Inn tteilri'i; ol seo.i| !0 „ 
was dieaier and tint impairment ol psychomotor Ocrlorm.nn.,, 
mme iiiiiiioiinceil <n the ekleriv Hie ami dependent dilli>ren C( , 
was dosnlv associated witn llu: cnirnsiionilinpit inoher pi., snil 
IriiKiilam concentrations measured m elderiv stiliiects. 

Palients with severe liver disease also domimstiated <jrejie t 
psvi'-hnmotor impairment ih.ni control subiects or patient; 
willt nniunial Itvn ovsltmcuon 

Pti,vm;icoxmaitcs Tri.irol.mi is r.iuidlv absoroed and cms; 
plasma levels an- reached within 2 hours loliowmi) oral aomm. 
(stratum. Peak plasma concentration (C „„) and area unoer 
me plasma-conoenlration curve (AUC1 increase in proportion 
to the dose, wmie the lime to peak plasma concentration 
(T„„). eliminatmn hall-lue (l '/><(). and clearance are inoecen- 
oen't ol dose. Triazolam has a short hall-lue. the rangj , s 
reported to be 1.5 to 5 5 hours 

Triazolam is metabolized via hepatic microsomal oxidation 
The hydroxytates metabolites, which are inactive, are excreted 
primarily in the urine as conjugated glucuroniaes. Tne tw 
primary metaboines accouni lor approximately 80% ot in e 
unnarv excretion 

Repeated administration ot triazolam tor ,■ days does no; 
lead to accumulation and does not alter the rate ol elimination. 
Pharmacokinetics in the elderly: The kinetics ot triazolam Jrs 
significantly influenced bv age (see Table I on following oagsj. 
Following single oral doses of 0. 125 mg ana 0.25 mg of ipj. 
zolam, peak plasma concentrations and area under the curve 
were significant^ higner and clearance significantly lower m 
elderly subjects (mean age: 69 years) than m younger ones 
(mean age: 30 years). Age. however, did not influence the 
time to peak plasma levels and differences in elimination hall- 
life were small. 

Pharmacokinetics in patients with renal failure Following oral 
administration of triazolam. 0.5 mg, peak oiasma tnazoiam 
concentrations were lower in 11 patients win renal lailurt 
undergoing dialysis (J.tM±1.83 ng/ml) than in patients wq 
normal renal function (6.54±1.7G ng/mL). Other pharmacoki- 
netic parameters were not significantly different between 
patients with impaired and normal renal function. 
Pharmacokinetics in patients with hepatic failure: Following 
oral administration of triazolam, 0.25 mg. triazolam clearance 
was reduced in 8 subjects with biopsy-proven ctrmosis 
(4,99^-3.14 ml/rnin/kg) as compared to 7 normal suoiects 
(669+2.52 mL/mm/kgj. Peak plasma levels and time to oeax 
concentration were not different between the groups. The 
reduction in triazolam clearance in subjects with cirrhosis cor- 
related with the severity ol liver dysfunction. 
Indications: For tne symptomatic relief of transient and snort- 
term insomnia in patients who have difficult;/ falling asieeo 
Triazolam is nol recommended lor early morning awakenings 
Treatment with triazolam should usually not exceed 7 to 
10 consecutive days. Use for more than 2 to 3 consecutive 
weeKs repuires complete re-evaluation of the oatient. 

The use ol nypnoucs should be restricted for insomnia 
v/nere disturbed sieep results in impaired aaylime functioning 
Contraindications: In patients witn known hypersensitivity to 
this drug or oner benzodiazepines. 

Triazolam is contrainoicated in patients wno in the pas; man- 
ifested paradoxical reactions to alconol and/or sedative medi- 
cations, and in sublets with a history ol substance or 
aiconol abuse. 

Preqnsncy; Triazolam is contraindicaied m pregnant wemen, 
Benzodiazepmes may cause fetal damage wnen administered 
during pregnancy. During the first trimester of pregnancy, 
several studies nave suggested an increased risk ol congenital 
matlormations associated with the use ol Benzodiazepines 
Dunng the las: weeks ol pregnancy, ingestion ol therapeutic 
doses of a benzodiazepine hypnotic has resulted in necnatai 
CMS depression due to transplacental distribution. If triazolam 
is prescribed to women of childbeanng potential, the patient 
should be warned of the potential risk to a fetus and aCvtsed 
to consul! her physician regarding the discontinuation d me 
drug if she intends to become p-egnant. 

Tnazolam is contraindicaied in patients wno have myas- 
thenia gravis or a history ol uncorrected narrow-angle glau- 
coma. 

Warnings: General: Sleep disturbance may ce the presenting 
manilestanon ol a physical and/or psychiatric disorder. Conse^ 
ouently, a decision tc inmate symptomatic treatm"' o 
insomnia should only m made after tne patient has Been care- 
fully evaluated 



Copy"0*i"S ''"'' C.i/iiKJMJ" l'h.vmami,tn.n testxaw Alt n-jnn nsnrmO 




HAU 



S97 



Table I — HJlcion . —_ 

SSmT«»«<""' «<»<^ *>*^*>**to ''^meters following Single Or.il Dose* of Triazolam In Y.mnq .ml 
Eldnrly Volunteers 



parameter 



Triazolam 0. 125 nif) 
Young Elderly 

(n = 2li) (" = 2D 



Triazolam D.25 mo 

Young Elderly 

(n = 26} |n = Z1) 



C™. f"<)""l-> 

U. (I") 

AUC tnij/mL.hr} 

f .-« (I" I 

Clearance (mUmin/kgl 



I. OS +0.08 
O.BiiiOOS 
3. 85 + 0. -15 
2.9.1+0.-1 
11 4 + 2.? 



1.67 jtO.16* 

95 ±0.11 

6.2.1+0 82" 

3.03 + 0.25 

G 11+0 9' 



2.O2 + 15 
0.9ii±t).IO 
7.01+0 68 
2 43 + l(i 
K!.S±1 



3 06 ±0.2:." 

o.iia ±0. or 

1 1103 ±1 IT 

.1011 + 0. 2-1" 

5 8 + or 



-Statistically sigmlicarit to' yotiiig versus elderly at indicated nose 



The failure ol insomnia to remit after 7 to 10 d3vs ol treat- 
muni may indicate the presence ol a primary psychiatric 
and/or medical illness 

Worsening, ol insomnia or the emernence ot new abnormali- 
ties ol winking or behavior may be tnc corisepuence ol 3" 
unrecognized psychiatric or physical disorder. These have also 
been reported to occur in association with trie use ol triazolam. 

Memory Disturbance: 

- Anterograde amnesia ot varying seventy has been 
reuorted tollowmg therapeutic doses ot benzodiazepines 
including tnazolam. Anterograde amnesia is a 
dose-reiatec phenomenon and elderly sublets may be 
al a particular risk. Data from several sources suggest 
that anterograde amnesia and next day memory loss 
may occur at a higher rate with triazolam man with 
oiher benzodiazepines. 

- Cases ot transient global amnesia and "traveler's 
amnesia" have also been reponed in association with 
tnazolam. the latter in individuals who have taken the 
drug to induce sleep while travelling. Transient globai 
amnesia and traveler's amnesia are unpredictable 3(id 
not necessarily dose-related phenomena. Patients 
should he warned not to take tnazolam under circum- 
stances in which a full night's sleep and clearance ot 
the drug trom the body are no: possible belore they 
need again to resume full activity (e.g.. an overnight 
flight ol less than 7 to 8 hours). 




Abnormal thinking and psychotic behavioral changes have 
peen reported to occur in association with the use ol benzodi- 
Kepme hypnotics including triazolam. Some ol the changes 
m3y be characterized by decreased inhibition, e.g., aggres- 
siveness or extroversion thai seem excessive, similar to that 
seen witti alcohol and other CNS depressants (e.g.. sedative,' 
hypnotics!. Particular caution is warranted in patients with a 
history of violent behavior. Psychotic behavioral changes that 
have been reported include bizarre behavior, hallucinations, 
jnd depersonalization. Abnormal behaviors associated wilh 
tnazolam have been reponed more with chronic use or hrgn 

doses, 

ft can rarely be determined with certainty whether a partic- 
ular instance ol the abnormal behaviors listed above is drug 
nduced, spontaneous in origin, or a result ol an underlying 
psvchiatnc or physical disorder, Nevertheless, the emergence 
cl my new benavioral sign or symptom ol concern requires 
careful and immediate evaluation. 
Contusion: The benzodiazepines atleel mental efficiency e.g., 
concentration, attention and vigilance. The risk of conlusion is 
greater in tne elderly and in patients with cerebral impairment. 
Anxiety, restlessness: An increase in daytime anxiety (inter- 
pose rebound anxiety) and/or restlessness have been 
Deserved during treatment with triazolam. This may be a mam- 
lerjDon of interdose withdrawal, due to the very snort eiimi- 
tuuon half-lite of the drug. 

Depression: Caution should be exercised if triazolam is pre- 
aenbed lo patienis wilh signs or symptoms ol depression that 
could be intensified by hypnotic drugs. Suicidal tendencies 
ti.. intentional overdose, is more common in tnese patients 
tus. the least amount of drug that is feasible should be avaii- 
ac« to mem al any one time. 

Ptwautiont: Drug Interactions: Triazolam produces additive 
0& depressant effects when coadministered with alcohol, 
wiftttiminei. anticonvulsants, or psychotropic medications 
-ten themselves can produce CNS depression. 
... Ptuumacokinetic interactions can occur when triazolam is 
••muttered along with drugs that interfere win its metaoo- 
tarn. Examples include crmctidme or erythromycin which 
■oaa coadministered with triazolam cause an approximate 
•oobKog ol the plasma levels and elimination half-life ol tna- 
Consequently, consideration Of dose reduction may 



hi: appro finale when patients are treated concomnanllv wilh 
triazolam and either cmnilidme or erythromycin. 

When a sinoKi oral 0.25 mg dose ol triazolam was co- 
administered with nelazodone (200 mg bid) al steady stale, 
triazolam peak concentrations, hall-lite, and AUC were 
increased 1.7, 3 and -t told respectively. The pharmacokinetics 
ol nelazodone were noi altered. The concomitant use ol tria- 
zolam and nelazodone was also associated with an increase 
in psychomotor impairment presumably due to increased tria- 
zolam plasma concentrations. The interactive effects of higher 
doses ot these agents have not been studied The concomitant 
use ol nelazodone and triazolam should be avoided 
Drug abuse, dependence and withdrawal: Withdrawal symp- 
toms, similar in character to those noted with Barbiturates and 
alccho! (convulsions, tremor, 30dominal and muscle cramps, 
vomiting, sweating, dysohona. perceptual Disturbances and 
insomnia! have occurrec following abrupl discontinuance of 
benzodiazepines, inducing tnazolam, The more severe symp- 
toms are usually associated wilh higner dosages and longer 
usage although patients given theraoeutic dosages lor as tew 
as l to 2 weeks can also have withdrawal symoioms. including 
daytime anxiety, between nightly doses (see Pharmacology 
and Warnings). Conseouently. abrupt discontinuation should 
be avoided and a graoual dosage tapering schedule is recom- 
mended ni any patient taking more than the lowest dose lor 
more than a lew weeks. The recommendation for tapenng is 
particularly important m patients with a history of seizures. 

The risk of dependence is increased in patients wilh a history 
of alcoholism, drug abuse, or in patients with marked person- 
ality disorders (see Contraindications), interdose daytime anx- 
iety and rebound anxiety may increase the nsk ol dependency 
in triazolam treated patients. . . 

As with ail hypnotics, repeat prescriptions should be limited 
to those who are under medical supervision. 
Patients with specific conditions: Triazolam should be given 
with caution to patients with impaired hepatic or renal func- 
tion severe pulmonary insufficiency, or sleep apnea. Respira- 
tory depression and apnea have been reported in patients with 
compromised respiratory function. 
Occupational Hazards: Because of triazolam's CNS depressant 
effect, patients receiving the drug should be cautioned against 
engaging in hazardous occupations requinng complete mental 



,111'ltllllSS SUCH -1'. 1HIIII.IIIIII1 rlUltlHIUTIV HI itMVIIK] ,1 nllllljl 

vi'tucli: I"' lln: li-ui"' riMsnn n.iUiint:; snmilil In- w.irniiil 
,iii.iin:;t llm eitiieimiit.ini nwraium ill In.i.-iium arm .uitiiimi oi, 
CNS i!nfHi:ss.ii!l niiio:; — 

Pmin.vtW For (nralniieini: erteets see Contraindications. Nrai 
lerali)i|enn: mines: a child bom lo A mmhei who is on tmnut- 
diazilpiiies m-iv he al siwie "sk lor withdrawal svmnimns trom 
inn drug dimiHl inn poalnai.il period Also, neimat.li ilaccirlny 
n.ii been reported m an mt.im born In a mother wlw ban oiirii 
receiving (lenzixliazeiwies 

Mcl.rwm Human stndier. have not been tie'twinnd inn studies 
in tats have shown lhat lriazoi.ini ami Us ineiahniiles are 
secreted m the miiK Iherntore administration ol tn.uoum lo 
musing mowers is nol recommended 
Children: Tim satelv and ellectiveness ol triazolam in children 
Billow llii! age ol IS have nol been established 
Geriatrics: Elderly paiiimis are especi.iliv susceptible lo dose- 
dilated adverse enacts, such as orowsmes;;. oizzmess, or 
unpaired ciwrrnnalioii. Thercloie. the lowest possible OOSe 
should be used in these subiects. 
Adverse EMects: The most Ireouenl adverse reaclions associ- 
ated wilh Ihe use ol triazolam are extensions ol the pharmaco- 
logical effects ol Ihe drug. e.g.. sedaiion [morning 
diowsmess, somnolence), dizziness, nervousness/irritability 
and impaired coordination 

The most serious adverss reactions winch mav occur 
include memory impairment, abnormal thinsmg/behavior. con- 
tusion, anxiety, and depression (see Warnings). 

The incidence ol adverse reactions among patients receiving 
triazolam or piaceoo is listed in Table II. The ligures cannot 
he used lo predict precisely tne incidence ol untoward events 
in the course of usual medical practice where patient charac- 
teristics and oiher (actors often differ from those in clinical 
trials. Comparison o! the died ligures, however, can provide 
the presenber with some basis for estimating the relative con- 
tributions ol drug and nonorug factors to the untoward even; 
incidence rate in Ihe population sludied. 

The adverse reaction prolile ol triazolam observed in con- 
trolled clinical trials illustrates the dose-oeoendency of most 
ot the adverse reactions. At present, the higher dose range 
is oof recommended (see Dosage) 

Rare (i.e., less man O.S'Si) adverse reactions include dyses- 
thesia/paresthesia, dream abnormalities, orug abuse/habitua- 
tion, drug withdrawal symptoms, hallucinations, muscle tone 
disorder, tremor, tinnitus, hearing impairment, eye irritation/ 
redness.' edema, chest pain, hot/cold flashes, hypertension, 
syncope, dyspnea, constipation. Ilatulence. oral irritation, mic- 
turition difficulties, dermatitis, diaphoresis, muscular cramps, 
muscular weakness, malaise, sexual dyslunction. Elevated 
levels ol AST. bilirubin, and alkaline phosphatase have also 
been noied. 

Overdose: Symptoms and Treatment: Manifestations of tria- 
zolam overdosage include extensions ol it's pharmacological 
effects, nameiy, somnolence, confusion, impaired coordina- 
tion, slurred speech, and ultimately, coma. Respiratory 
depression and apnea have been repon=c with pverdosages 
to tnazolam. 



<- 



Table il-Halcion 



Percent ol Patients Reporting Adverse Reactions (aO.S'/o) 



Body System 
CNS 



Adverse Reaction 



Triazolam 
0.1-0.3 mg 

N = 1002 



Triazolam 

0.4-0.6 mg 

N = 2370 



Placebo 
N = 2D36 



Metaoolic/Nutrttian 
Special Senses 

Cardiovascular 

Respiratory 

Gastroiniesnnal 



Musculoskeletal 



drowsiness/seoauon 

headache 

dizziness 

nervousness/irritability 

impaired coordination 

insomnia 

conlusion 

mood changes 

depression 

memory impairment 

appetite change 

visual disturbance 
taste alteration 

palpitations 

respiratory inlecnon 

nausea/vomiting 

dry mouth 

abdominal pain/discomlon 

diarrhea 

rnusculoskeletal/iomt pain 



9.5 


18.6 


14. a 


5.9 


3.1 


6.2 


4 & 


9.0 


5.8 


3.7 


4.6 


6.4 


1.7 


4.3 


1.2 


1.0 


1.2 


2.8 


0.7 


1.0 


0.5 


0.7 


0,8 


0.7 


0,5 


1.1 


07 


0.2 


1.0 








0.5 


0.6 


0.4 


0.7 


0,2 


0.4 


0.6 


0.3 


0,5 


04 


0.4 


1.1 


1.7 


0.9 


2.9 


3.8 


3.5 


0.5 


0.9 


1.4 


0.4 


0,6 


05 


0.2 


0.8 


04 


OH 


0.9 


0.7 



► 



Cops""?'" S '»'-«> Cj'Wlnn Hu,tm:„:>;>lf>;:il A:'-t,o:,t>',r. AH ngnu 



tosa'vod 



598 



HALD 



llitaon (cwif'i'i 



V 



Hutu n.n; Oeen reported i" association wish overdoses oi 
iri.i.Mi.nii nv itseil. 35 il njs win oilier uen;mtia;epine> "' 

,10. m l.u.iiilies have own reported «' pnnenis wiin nave 

nveronseii with .1 comnmanon 01 alcohol and a simile ben.-iuii 
3/.,:ume. iiicuiimo. triwolani In some ill these casus biond 
levels oi urn nen;odia,>eoine .litd alcohol were lower in.in ihos: 
usuniiv associated wiin tenons ol totalities «fi either sun 
stance alone 

As in .in cases ol drug overdosaoe. respiration pulse am, 
blood piessure snould tie monitored and suonorted bv general 
measuie wlitiii necessary Immediate gastric invade should no 
periomied An adenuaie Jitwnv should Be nviimaincd i V 
Hun!:, mav oc administered As wKfi the mnnaoeinenl ol intui- 
tional overdosage wiin anv aruc;. Ilu: privsiciari snould bea' »> 
mind uint multioie agents mav 'iavc Boon ingested By tne 

Pillion; 

Trie beii.:odia;eoine antagonist, !liima:eml. is a soecihc ,iw- 
coie m known or suspected oenzoniareDiniJ overcose (For con- 
ditions ol use. see Anexate oroouci monograph.!. 

experiments in animais nave indicated that carciooulmcnarv 
coliaDse can occur with massive i.v. doses ot tnazoiam mis 
could be reversed wiin ocsmve mechanical respiration anc : v 
mlusicii ol noieomephtine Ditanraie or metaraminoi buan.ai;. 
Hemodialysis and lorcco oiuresis are prooaDly a>. tunc vaius. 
Dosage: The lowest effective oose should Be usee Treatment 
wilh triazolam snould usually not exceed 7 to 10 consecutive 
days. Use lor more than 2 io 3 consecutive weens rcouires 
complete re-evaiuanon ol trie palient. 

Tne starting dose in all patients should be 125 mc: lor 
many patients (tits dose immediately Before retiring should be 
sufficient, in most adults. 3 dose ol Q.25 mg snould net be 
' exceeded. A dose of 0.5 mg should Be used only for excec- 
tionai patients who do not respond adeouateiy to a trial of trie 
lower dose since the risk ot several adverse reactions 
increases witn tne size of the dose administered 

for elderly, or debilitated patients and patients with dis- 
turbed liver/kicney lunction. trie dose snoulc not exceed 
0.125 mg belore retiring. The 0.25 mg dose snould he used 
only lor exceptional patients who do not respono to a trial oi 
the lower oose, 

Inlormation lor the Patient: See Slue Sectipn-lnlormanon 
for trie Patient "Haicion". 

Supplied: 0.125 mg: Each violet, scored tablet Branoed 
"Upjonn 10" contains: triazolam 0.125 mg. Nonmeracmal 
ingredients: cellulose, cornstarch, docusate socium. erytnro- 
sine sodium. FO&C 8!ue No, 2. lactose, magnesium stearate. 
silicon dioxica. Gluten-tree. Blister packages o! 7. Store a; 
controlled room temperature (15 to 30°C|. 
25 mg' Each powoer biue. scored tablet Branded 
■■Upjohn 17" contains: triazolam 0.25 mg. Nonmedical 
ingredients: cellulose, cornstarch, aocusale scaium. r06C 
Blue No 2 lactose, magnesium stearate, silicon Sioxiae, 
Gluien-lree. Buster packages ot 7. Store at controlled room 
temperature [15 to 30°Ci. 

(Snovtn in Product" Recognition Section/ 



HALDOL* 

McNeil 



Haloperidoi 



Antipsychotic 



Pharmacology: Halopencot is a buiyroonerone cenvative with 
antipsychotic properties mat has Been considers particularly 
effective in tne management ol hyperactive, agitation, anc 
mama. Halcoendol is ar. effective neuroleptic anc also pos- 
sesses antiemenc properties; it has a markec tendency to 
provpke extrapyramidal effects and ha; relatively weak alpha- 
adrendlytirpropemes. I; may also exhibit hyesfnermic and 
andrexian; effects and potentiate the 3cfion of Barbiturates, 
general anesfhetics, anc otner CMS depressant drugs 

The mscnanism of action of naicpendpi has no; Been 
entirely elucidated, but has been attriouted to ins inhibition of 
trie transport mechanism of cerebral monoamines, particularly 
by blocking tne impulse transmission in dopaminergic neu- 
rons. 

Peak plasma levels of naloperidoi occur within 2 to 6 hours 
ol oral dosing and about 20 minutes after i.m. administration. 
The mean plasma (terminal elimination! hail-life has oeen 
determined a: 20.7 ±4.6 fSO} hours, and aimo.gn excretion 
begins ra-jiriiy. only V. to 60% ol moested :•>.'. oactive drug 
is excreted (mainly as meiahoines in urine, seme in tec'isi oy 



111,. ,.,iil "I ""' '"HI wtiitk. and vi:rv small Hut diilnr.l.ilin! t''<" ! '"- 
„t r.uiiincnviiv o.irsml m the ulonti ami aie evcreieii lor silver* 
weevs allei Uosini) Athisn ltd ol ine innesloil nose is ii:i.i> 
wit\\ uiicliaiHied in tin? uriim 

lixlicitiiins: HaioDiirmnl is mdiMieil us tlw riun.meinenl nt 
niiiiiieqalions ol ar.uie and cnriinu: DSvcliosm. iiicliuliin; 
sriii-nonienia and maim: stales It mav also Ik nt v.ilue in ttf 
m , llU[ll ., ni .„t ol agnressive and .utnaled lienavioi ■» uatienl:; 
w,i» i-riromi; Dmih sviiiirome and nieni.ii relaidamw am: m 
H„. sviuplom.llu: control ol GilleS de la Tuunilii! s svnitiom,' 
Caiitraiiiiliealions: Comatose states and CMS depression do- 
m .ik'unni or otner depressant drugs: severe demessive st.xe;.. . 
previon; smsiii: diseases: lesions ot me Basal pamjiia: t'.n- ; 
k.nsiin ■■; svnnrome. exceoi in the case dl ovskines.as due to ; 
levooooa rreaiment; sensitivity 10 natognnclol: senile oanenu: 
wiiii i«e-e<i3linil Parkinson-like svmotoms 
Cliiioren Saletv and etiecnveness m voung ctnldren nave mi: 
Dsen csiabiishcd: Ihcrelore. haloperidoi is conirainoicaUHi i« ; 
tms ane (jiouo ■ 

{"ewncr and (.ncutorr Saleiy for use in pregnancy and ■ 
Mention has not been established, do nol aominisuv io ; 
women ol cMdBeanng potential or nursing mothers unless. ; 
,n in- opinion ol me pnvsician. the expected benelits o, tne 
tlruc ouiweicn tne potential hazard io the tetus or child Haw- ; 
pemiol is excreied in breast milk. 

Warnings- Tardive Dyskinesia: Tardive dyskinesia is known so l 
occur m patients treated wiin neuroleptics with anlipsvchnlic j 
prooerties ant: other drugs with substantial neuroteohc : 
acfivitv Althouob the ovskinenc syndrome may remit partially . 
or completely ti the meoicalion is withdrawn, it is irreversible 
in some patients. At the present time there is uncertainly as i 
to wheiner neuroleptic drugs difier in ineir potential to cause j 
tardive dyskinesia. | 

Since there is a siamticant prevalence m this syndrome , 
associated with the use of neuroleptic drugs, and since there j 
,s no known effective treatment, chronic use ol these arugs , 
shouio generally Be restricted to patients lor whom neurolep- ; 
t,cs are known to be eltective and lor wnom there is no aitema- . 
tive therapy available witn better risk acceptability. H 
maniiestalions of tardive dyskinesia are detected during the 
use of a neuroleptic, tne drug should Be discontinued. 

The risk of a patient developing tardive dyskinesia and ci 
the syndrome becoming irreversiole appear to increase with 
th° duration ol treatment and the total amount Pf arugs admin- 
istered although, in some instances, tardive dyskinesia may 
oevelop alter relatively short periods of treatment at low 
doses The risk ol developing tardive dyskinesia may. mere- 
lore Be minimized by reducing tne dose of me neuroleptic 
! orug used and its duration of administration, consistent wi,n 
1 m» effective manaoement ol tne patient's condition, con- 
tinued use of neuroleptics should be periodically reassessed. 
i Withdrawal Emergent Neurolooical Signs: Generally, patients 
I receiving short-term therapy experience no problems with 
; aorupt discontinuation of antipsychotic drugs. However, some 
' patients on maintenance treatment experience transient oyski- 
- netic signs after aorupt withdrawal. In certain of these cases 
i the dyskinetic movements are indistinguishable Irom the syn- 
: arcme described under Tardive Dyskinesia except tor duration, 
j H is not knewn wnether gradual withdrawal ol antipsychotic 
! aruos will reouce the rate ol occurrence of withdrawal emer- 
: g»n; neurological signs but until lunner evidence becomes 
available it seems reasonable to gradually withdraw use oi 

■ antipsychotic drugs. 

■ An encephalopathy syndrome (characterized by weakness 
i lethargy fever, tremuiousness and confusion, extrapyramidal 

symptoms, leukocytosis, elevated serum entymes. BUi- and 
] F3S followed By irreversible Pram carnage) has occurred in 

a lew patients treated with lithium plus haloperidoi. A causal 
> reianpnshtp oetwecn these events and the concomitant aomin- 
i istrat.on ol lithium and haloperidoi has not been established, 
! however patients receiving such combined therapy snou.d be 
! monitored closely lor early evidence of neurological toxicity 
i and treatment discontinued promcuy il such signs ad«« r - 

Elderly or debilitated patients receiving the drug should oe 
; car«fuliy observed for lethargy and a decreased sensation ot 
I tmrst due io central inmoiiion which might lead to dehydration 
: and reduced pulmonary ventilation and could result in compli- 
I cations such as terminal bronchopneumonia. 
i Occupational Hazards: Although haloperidoi is a relatively non- 
i sedating neuroleptic, sedation may occur in some patients. 
I Therefore physicians should be aware ol this possibility and 
! caution patients aoout tne danger of participating in activities 
■ requiring cpmplete mental alertness, lodgement and physical 

coordination, sucn as driving and operating dangerous 

Haloperidoi may prolong the hypnotic action ol Barbiturates 
and may poienliate iru: etlecis ol alcohol and other CNb 



iii'ii'esi'.ani cuius such as aiiesmeiici. an.l ii.ireniii:: [:,„]„„, 
r.H.iuki tiii'ieio'i' tie eM!ii:e;ed when n is used wiin .uirm , „ r 
Hie; (viie am; jiliin'.lineiil:'. m men unsane mav Be nniiiin : [| 
fiecaiiliuns' AiUniiiisiralion in iiaiients witti seveie i:.ik!i, u: 
iiivoivemem srwiili! tu: unaided mispite Hit 1 I.m! Hi.il li.iimn:, 
iiw 1 is well tolerated liv patieuis with cunuii: maiiltir.icncv , 



m.i: ii has been nsnl wiin lavor.ible resuils Io m.init.n,, n, r , 
eau'.iiiv.isciii.ir luncimn of oaimuis with w-'jvc crises In vl]v . 
i.ue instances, if has been lull ma: h.ilramridol was c;)ni;ii i(i 
i,hv to inn orccioitaiion ol attacks in aniini.i prone pan,;,,!- 
Mcuerale livnolension mav occur wild parenlernl administfj 
ti s - : or excessive oral doses ol haionendor however, vertex 
an.; svneone occur onlv rarely 

Haiofiitntl: nuv lower the convtilravt 1 ihrnsholn ami has 
been reported io mount seizures m o'.ivkkisIv -.--tntrnlit:: 
known epiieoiios VVnen instiluunc lialopenccl llicr.inv m m C se 
palienis. ailcciuald anticonvulsant medication should oe mam. 
Mined conccmiianilv 

As with otner antipsychotic aoents, haiooeridol should p,. 
nommisiered caunouslv to patients with severe impairment oi 
live; or kidnev function, and 10 O.llients with known allerine; 
or niston,' ol allergies to other neuroleptic diugs. Caution i>. 
also advisee in patients with pnecchromocyioma ann condi- 
tions predisposing lo epilepsy, such as alcohol withdrawal am; 
brain damage 

Haloperidoi nas lowered cholesterol concentrations m ine 
setum and liver ol monkeys. An accumulation ol desmosteroi 
has been ooserveo in tne serum of rats given repeated high 
ooses (10 mgAgl of halopenool. In man, mild transiem 
decreases m serum cholesterol were reported in preliminary 
sluoies. However, in a study involving a group ol scnizo- 
pnremc panents on extended medication, sigmlicant lowering 
of serum cnoiesterol was not observed with halopenool. anc 
mere was no accumulation of desmosteroi or ?-denyorocno- 
lesterol. A sionificar.i lowering ol cholesterol together with 
accumulation of anoiner sterol ipassioiy 7-oenydrccnolesteroli 
has been reported in patients receiving a chemically related 
drug (trifluoerioPl). and skin and eye changes (ichthyosis anc 
cataracts! have occurred clinically with another butyropnenone 
derivative. Skin and eye changes have no; been noservec in 
panents receiving naloperidoi. However, all patients receiving 
haloperidoi tor a prolonged period ol time should be carefully 
ooserved lor any cnanges in the skin and eyes. If such 
changes are seen, discontinue tne drug promptly. 
j Drug interactions: Haloperidoi has been reported to interfere 
j with the anticoaoulant properties ol pnemncipne in an ispiated 
cas» and me possibility should be kept in mind pf a similar 
effect occurring when haloperiool is useo with other amicoagu- 

lants. 
I Haloperiool may antagonize the action ol epinephrine anc 
older sympathomimetic agenis and reverse the blood pres- 
sure-lowering effects of adrenergic-blockmg agents, such as 
guanefhidine. 

enhanced CMS effects may occur when haloperidoi is usee 
in combination with metnyldopa. 

Haloperidoi inhibits tne meiaGoluation of tricyclic antide- 
pressants, tnereoy increasing plasma levels of these drugs. 
This may result in increased tricyclic antidepressant toxicity 
(jniicholmergic effects, cardiovascular toxicity, lowering ol 
I seizure tnresnold). 

1 v/nen proionoed caroamazeome treatment is added to haio- 
1 pondol therapy" this results m a signilican: reduction ot halo- 
j peridol plasma levels. Therefore, Curing comninattpn 
! treatment, me haloperiool dose should be aoiustec, wnen nee- 
I essary. After stopping caroamazeome. it will be necessary to 
! reduce the dosaoe of haiopenooi, 
! Halopenool may impair the antiparkmson effects o. levo- 

~\l an antiparkmson aoent is used concomitantly with halo- 
p-ndol bom drugs snould not be discontinued simultane- 
ously, since extrapyramidal symptoms may occur due to the 
siower excretion r3te ol halopenool. 

The physician should keep in mind the possibility of an 
increase in intraocular pressure when anticholinergic drugs, 
including anuparionscn agents, are acministered concomi- 
!2nilv with haiopenool. 

v/nen haiooeridol is used to control mania in cyclic diso.- 
cers ther» may Be a rapid mood swing to depression. 

The antiemetic action of haloperidoi may obscure signs ol 
toxicity due io overdosage of other drugs or mask tne symp- 
toms ol some organic diseases, such as Oram tumor or intes- 
tinal obstructions. 

Severe neurotoxicity (rigidily, inability to walk or talk! ma/ 
occur in panents witn thyrotoxicosis woo are aico receiving 
antipsychotic medication, including haiooeridol. 

Carcmooemciiy studies in mice (16 months) and rat, 
(2-s nipnlii' i snowc: a significant increase m mammary giauu 



Con-mnM % IVJ'J C.in.-,'r..i» Mi.-ini);,t,i;i,:«:,->t /•■,■,',-:««;' 



Qi.i:i'.ir.:;;s |t:<v.' .f 



ui.i.'iiii.iui Ci.treu.im r ;riniiii! hi' nsnd hi cno:;<: ii.uthis wiin 
caution ,uM in low .limits to iiii'Ctudi: iiiivulonnieii; jl alnxi.i, 
snil.uiuii .m.l outer possible JiMersi! elleels 
tmoiiiiiul Disnroi'rs Oi.L'iiihtm is no[ ^^!:omiTiim^!<:iJ in the 
inuliiii'ii; ot uitvchotic or nuviiniiv netinisSKl patients I'recau- 
lions ,uc niilicatiM lor sewtreiv iicorcsiliU paitents or Ibuse 
wiiii siinw ,tiw evidence of tiiiwrrnjiiiii ileiiiussiiiu. o.uticul.inv 
in the rna'dinnon that siuciil.il tenituncins iiuy tin present .liii; 
protective measures mav Hi: uecessaiy 

Smci: excilement and h'.Iki paradoxical nMOliiins nuy rcsull 
Irom tisi! ill [tit: drug in (lsvclralio uaiteiils. dia;eu.un should 
not be used 10 arr.tiutaiory patients suspected ol n.ivuig psv- 
chotic tendencies 

Use unlurc ilroncioscouv Jral Urvntioscuuy: Since thorn .ire 
insullii:ii!!i: il.ii.i .'.x.iilabfi: to establish me saterv c-i uia;er>.im 
orior 10 bwnchusc'ov and laryngoscopy, us use is not rccani. 
niuiiilo J 

Use OeMr; il.istroscaoy Esonn.igoscopy. Cardioietsion ano 
Surqic.il Procedures: Oiueoam snould 0e usee cmy under 
conditions in wmen safcgiiaras arc available should iaryngo- 
Spasm and circulatory or resolutory depression occur. 

Since .in increase in caugn rc(!t=x and l.iryngoso.ism occur 
wim peroral endoscopic procedures, (no use ol .1 tocical anes- 
luetic agent and tne availability ol necessary counter measures 
are recommended. 

Concurrent use ol narcotics and bnrOituraics with ciazepam 
may produce a potsntiation ol effect and, ^vhers such comorns- 
lions are usee, appropriate reduction ol aosage is .-egutrcd. 
Impaired Senai anc Hepatic Function: The usual precautions 
in treating patients witn impaired heoatic function snould De 
observed Since rn;:aoolites ol diazepam are excreted by me 
kioney. in crcer tc avoid their excess accumulation, caution 
Should De exercisec in the administration ot the drug to 
patients witn compromised kidney luncticn. 
Potentiation ol Orug Effects: Careful consideration stiould be 
given it diazepam is :o be used concomitantly with otner psy- 
chotropic agents such as pnenotbiazines, Partnturates. MAO 
irtmbnors and ottier anuaeoressanls. since me pharmacolo- 
gical action ol tnese agents may potentials the action of di- 
azeoam. 

Oue to tne possible poiemiation o( eftecis and the occur- 
rence ot aaverse reactions, patients should oe acvised to 
aosiam from CMS oeoressant drugs during treatment wim 
diazepam. 

The clearance o! diazepam and ol certain other oenzodi- 
aiepmes can be delayed when used in association c( aman- 
dine. 

Parenteral dia2»bahi has produced hypotension or muscular 
weakness in some patients, particularly when used wtiti barOi- 
turates. narcctics and alcohol. 

General; Alter administration ol diazepam, ambulation 
should be delayed unfii complete alertness is restored. 
Adverse Eflects: Evidence suggest mat mere is a lew inci- 
pence of local reactions wnen Oiazemuls is used. 5ica eflects 
most commonly reooned 3re orowsmess. latigue and ataxia. 
Otner aoverse reactions less Irequentty reported mcx'ce: 
CHS: conL-sicn, aeoression, dysarthria, neailache. nypoac- 
tivjty, slurrsc soeecn. syncope, tremor, vertigo anc Itoppy 
infant syndroms. 

Gastrointestinal: constipation, nausea 
Urogenital: incontinence, changes in libido, urinary retention, ■ 
Carciovascular: Sraoycardia. cardiovascular collapse, hypo- < 
tension, venous mrornoosis and onlebms at site ol injection. 
Cohinatmoiogical: oiurred vision, diplopia, nystagmus. : 

Oermatologicai. urticaria, skin rasn. : 

Ower: hiccuss. cnanoes m salivation, neutropenia, jaundice. ; 
Paradoxical reaction: such as acute hyperexcited sta::s, anx- 
lery, hallucinations, increased muscle spasneir/. insomnia, 
rage, sleep cisturpances and stimulation have been resorted: 
s.iould tnese occur, use ol the crug should De discontinued. 
Minor changes in t;G patterns, usually low-vcita - ;? fas; 
activity, have oeen opserveo m patients dunng anc sher di- . 
aiepam therapy and are of no known significance. 

in oeroral encoscocic procedures, courjning, depressed res- ■ 
siratton. dyscnea. nyoervenntatfon. laryngosoasm anc pam in : 
Itiroat or cnes; nave Seen reported. '. 

Because o( isolated reports ol neutropenia and |?undice. 
periodic diced count; ana tiver lunction tests are acvisaole 
Cunng long- ! e'rn therapy. 

O-jerdase: Symptoms and Treatment: Manilestatic.is of 
cmecam overcome include somnolence, confusion, coma . 
and cimimsnec refle/es. Respirauon. pulse and blood pressure 
cnould oe monitored, as m all cases of drug overdosage, 
although, m general, tnese etlects have been minima unless 



I 



iiviiiitiise is i'v;ii''i'e v'u'in'f.n siiiiiiiiiMi' iiummiics r.liiiuM '"'' 
■ miuiliivrit. .Hinhl Willi i v fliiuls .nil] .in .lili'ilu.ll!^ .ni^v.lv itMJ'i 

lanithi Hviiiiii'i^"!'! in-^ "'' comiiiittiii: :iv inn usi' >>' l*iv."ti b - 
: reiwl DiJlvsi:; ;^ '»! luiiii.nl v.iiin: 

I Dut.iae: Uns.uii' sliuiiih t>i' uHlivi(lii,iii;i'ii '•■» iiuxnn.il II <'■ 

I ct.il eliect. Tint usual ruciiiiniieoiieii ,iosi' m inner ,:bitilnw .uiit 

, .idulti f-Huses tniiii L 1 tc u! tun i.rti >'; ' " ■ daiemiini] on tin: 

J imlic.iimil anii.t'.- inn smentv jt inn ni-iuuiinii isne Oos.iij'' '>" 

; siiiioif": "idio.ilhHisl In .lcuie conditions tint inuictnHi ni.iv Se 

; rcpe.ited within I tuiiK. although an mii'ival ol j io -I luui" 

I ts usually saiisi.tc.uny. 

! When J coniHiuinil mug ellecl is recui'eif. Inw<'t .loses iusu- 

| affy - to 5 n«)i mm snuil increments ;l «ecess.w\. shoiinl Sn 

t used in elderly nr ileOilu.itiM pjimnts Jji<i when otner sdU.iiiu 1 

I diugs am aiiiniiusiered tsee Warnings anil Anverse Ellects) 

For dosage in irediainc use. see Cos.'.oe .nut VV.irniiips 

■- Hectuse ot us ilituved action Cijjiniiiis is not reca::i- 

| menoed lor the ni.in.ioemeni ol status euiiepticns 

i l.V Use: Di.i;s!!'.i!is shou.C be injectec Slowly. tjMiiO 31 : eJ5l 

! 1 minute lor e.icfi S mc it mLI aoniinistered. Evtrenie care 

' should be taken to avoic rntra-arrenai aaministralion or 

: extravasation (see Warnincs, oanicuiai'v lor use m chitorsnl 

i When i.v. use is indicateri. Ijcillhes lor respiratory assts- 

i lance should he readily available. 

! When used i.v.. Oiaiemuls should be injected directly 

i into the vein wilhoul prior dilulion or minng with other 

i products or solutions, Oiaremuls ma\. however, cs mixed or 

i diluted with inti'itidiuVNui.'aiiGHi, bu( SuJ.i a mixture should be 

t usee within 6 hours. I' d ;3 not teasiaie to administer Cia 

jemuis directly :.\., 't may be miectso stowiy through t. 

ihlusion tubing as close as possible ;c the vein insertion 

: Oiazemuls has oeen shown to be incompatible with mor- 

' phme and giycooyrrolate. Mixing or further diluting Ciaiemuis 

I with products or solutions other than its own emulsion base 

! (Intralioic or Nutralioid) may de-s:abiii:e the emulsion. 

j Atlhougn such an etiec: msy not be recognizaote on visual 

I inspection, it could give nse to potinnatiy serious adverse 

■ reactions, Polyethyiene-linea or glass miusion sets and poiy- 
[ ethylene/polypropylene plastic syringes sre recommended for 
i use with Oiajemuis, Do not use inlusion sets cpntaimng poty- 
i vinyl chloride. 

i t.M. Use: Oiazemuls should se injected deeply into the muscle. 

| Adults: Acute anxiety or tension states related to stressful 

I conditions or non-psychotic emotional cisorders when paren- 

i serai administration is required. Depending on seventy, 2 to 

| 10 mg, t.m. or i.v. Repeat in 3 to 4 hcurs, il necessary. 

i Acute alcohol withdrawal: As an aid in symptomatic relie! 

f ol acute agitation, tremor, impending or acute delirium ire- 

I mens and hallucinosis. Iniiiaily 10 mg t.m. or i.v,. then 5 io 

< 10 mg in 3 to 4 hours, it necessary. 

, Minor surgical procedures including esophagoscopy and 

l gaslroscopy: as an adjunct m relieving anxiety slates tnat may 

j he present Before these procedures. Approximately 5 to 

| 10 mg. i.m.on.v.. as reouired. about 30 minutes ener to pro- 

; ceoures. 

■ For the relief of muscle scasm in ce:=sral palsy, athetosis 

■ and stiff man syndrome. Initially. 5 to 10 mg i.m. s; i.v., [hen 
5 10 10 mg in 3 to - hours, if necessary 

Pre-operative medication lor the retiel of anxiety stales. If 
premedications ctner than stroome s-Jlaie. scopolamine 
hydrobrcmide, mependme c: fentanyl c.'traie are cesired. they 
musi be administered in sec-rate syringes. Extreme cauttan 
musi be exercisec m panecis with enrcnic lung disease or 
unstable cardiovascular states. 10 mg i.m. or i.v 1 :o 2 hours 
before surgery. 

Cardioversion: to relieve anxiety anc tension anc :o reduce 
recall ol procedure. 5 to 15 ~g. i.v.. within 10 tc JO minutes 
prior to procedure. 

Children: See Warnings. Dosage not to exceed 0.35 mgftd 
slowly over a 3 -minute penes. 

Genalncs and Desmraied: Se: Precautions. 2 to 5 mg, i.m. 
or i.v. 

Once tne acute symptomatology has ;«n p.'Caeriy con- 
trolled with Oiazemuls me catient may s; placed on dral 
therapy vnth diazepam il lunr.er treairr»n: is recuirac 

Supplied: Each mL contain; diazepam : . mg, dissolved in the 
oil pnase ol an oil/-«ater emission, comsounded ■m-n purified 
soyoean oil 150 mg, acstyiaitd monogiycendes SO tig, pun- 
ned egg pnospnoiiDigs 12 mg. glycerol 22.5 mg anc sodium 
hydroxide io adjust oH to zssrcximateiy i. Oiazjmuls is a 
sterile formulation ar.g coniains no pre;er,at,'ves. it :-, intended 
for iv v i.m. use omy. Ami-is ol 2 ;r.i. packages ol 10. 
Siore at conirollid temperature bmow 2:'C. 0r ' '■■'.' I^Eez? 



DIAZEPAM 17) 

Gr.'iicrcrfjWonccraph. CFhA 

Benzodiazepine ^ — 

Pfiafimicnlugy: Di.i;uii.im niiisiinsiin sihI.iiht. hvnnou,- jm,. 

j nivlic. muscle reinxant ,irhl ,ifi!if:onvuls.iiit ainueni,!^ Mivu 

1 Uk .irtliinis ol Diriuinti.ireiiiin's .luon.ir ti' ,-esiilt mini |)u. 

■ pun-nil, limn ill neural inhihitiim nwiiutcii tiv c.iuim.i aniiiMon. 

■ tyrm .icul (CAOAI in rim CMS Di.i.-i:!!,iin acts siiluclivdiv nu 
' pulvsvnaolic iiutiroiial u.imw.iys ami m.iv ninihit or .i[iom CT | 
' transmission, unpenning on tin: eiKUgi'nuus lunchen ol 

GAISA 
: pn.vi:\.\cnkmi!Kr.s. Oi.'i;noJiti m wnil .ip.iiiihikl ,il;er oral acniti- 
islriiiiiin witn peak blond snvtis inacnmi hi i :o ; houra Fol- 
lowiiid i.v ailmiiiintrtstiiiii. peak tiioml levels occu: hi 
llj niiniiies The absorption of tli,wiur:i is r.tcid alter nxii\ 
admii'istrtltioii but tends to On slow and erratic after liti ,ivec- 
hod Diazepam is widely distributed to .Hi bcov tissues jnd 
crosses the placenta and the SlooiMirain barrier. The ccn v -:n. 
traiion m the CSF is acoroximately sbu.ii to me concentration 
of tree drug in the plasma, Br.lin and olasma di.lzeoam ieveis 
drop rapidly after milial i.v. mieclions as the drug is distnhuted 
to other tissues in the central comoartmeni. Ciizcoam is 
metaoonzed by ihe liver onmanly to active metabolites. Two 
ol its aciive metaooluos, N-oesnie!n\ic;i:saam and 
N-inethylox32eoam are further melaDOti;ed tc oxazepam t,hen 
coniugated with glucuronic acid and excreted. Elimination is 
prolonged in elderly or very young patients as well as in 
patients with liver disease. Atlhougn ciazeoam nas a long ,ia:i- 
lite it snould be administered m diviceo doses to present 
excessive sedaiion following rapid aOsorption ot large coses. 
Indications: The short-term symoiomalic reiier of mug to 
moderate negroes of anxiety 

In acute alcoholic withdrawal, diazepam may ce useful m 
tne symptomatic relief ol acute agnation, tremor and 
impending acute delirium tremens. 
In the ireatment ol status epilepticus and rscurrem secures. 
As an adjunct tor the relief of spasticity in neuromuscular 
disorders such as cerebral palsy, multiple sclerosis and athe- 
tosis. 

As a premedication tor anaesthesia, encosccoy and other 
minor procedures. 

Contyalndicalioni: Known hypersensitivity to diazepam or 
other benzodiazepines. In myasthenia gravis, acme narrow- 
angle glaucoma and infants under 6 months ol age. 
Warnings: Diazepam injectable should not be administered to 
patients in shock or coma. Rare reports of apnea or carciic 
arrest have been noted, usually following i.v. administration, 
Those aflected are usually elderly or very ill, those with limited 
pulmonary reserve 3nd those who have received recenl paren- 
teral barbilurales. Rosusciative resources should Se avaitos. 
Since lingual obsifuchon of the airway may occur, panicularr/ 
in children and in the elderly, caution is reouired to maintain 
a free airway in patients receiving diazepam miectaolc. 
Precautions: Emotional disorders: Diazepam is not recco 
mended in psychotic or severely depressed pahentc. Cannon 
is required in Ihe treatment of severely depressed patients cr 
those who show evidence of impending depression, pacpu- 
lariy the recognition Ihal suicidal tenoencies may be presen; 
and protective measures may be necessary. Since excitement 
and other paradoxical reactions may result Irom th; use ol ™,e 
drug in psychotic patients, it should not be used in amoulatcry 
patients suspected of having psychotic tendencies. 
Epileptic patients: Diazepam is nol recommenced a a sufctr,:- 
tuts lor standard anticonvulsant medication in the long-term 
control of epilepsy. It is indicated in Ihe treaierr.em of stacus 
epilepticus: however, appro pnaie anticonvulsant therapy 
snould be instituted as soon as passible after the intefruoccn 
ol status epileplicus. Diazepam should oe usee wim cautcr. 
for other indications in these patient; because a may indue; 
or aggravate seizures. Undsr these circumstances, dosag; 
ad|ustwenl of anuconvulsant medicaaons may 5e required 
Drug dependence: Abrupt cessation of la;ge coses of diaz- 
epam aRer prolonged penocs may preciorate acute wro 
drawal symptoms, including seizures. In these cas=rs, the drjg 
should Se discontinued gradually. Cauhon snould se exercs« 
when it is considered necsssary to administer diazepam v, 
addiction prone individuals. 

Premedication lor procedures: Diazepam iniectapie should y. 
used only under conditions m winch safeguard; are avaita 
should laryngosDasm and circulatory or resoiratory depressicc 
occur. Concurrent use ol narcotics and baroitura'e; wilh d:a- 
eparn injecaPle may produce a potentiation ol litest. Apprc-- 
pnate reduction ol dosage is required 



'S,b /ht)ft! '^ ,r t y-. * r ;,twn!>;iti Ph;(!tn;i>;nutFM\ k-.'JMlb'S. Ml ir;t:". K-.'Jit ■*:<} 



To mmmm (ho possibility of Ohlcbins. i.v. iniecuuiis should 

be miue directly mio a woe !umw v,!ssd - '"^ ' ,s al1 imcu ', 
b,ui «nn. lUio o! administration Should ml exceed ; 

5 nig/minutc. , ] 

Ase.d intn-arteiial iniecllon Otis to the n;k o< necrosis . 
Gccuoition.il Hazards: Patients receiving dia;coam should bi - 
3jvlS( . d , proceed cauliousty wherever mental alertness am. , 
™al coordination arc rcuuircd. Aher oarcntcral adrmn.ar.v ; 
Hon ol diazepam instable, angulation should be delayeu at . 
leist l or 3 hours of until complete alertness is restored. j 
Crus wmcwk AnDC.es: Antacids may decrease the rate 
but rot me extent of aosorplion of diazepam when adminis- 
tered concurrently. . . 
CMS depressants: Benzodiazepines may enhance me i^a 
de-ressanl effects of drugs including alcohol, anticonvulsants. , 
barbiluraics. MAO inhibitors, narcotic analgesics, phenotm- 
ain-'S and tricyclic antidepressants. 
Disultiram: Oisultiram may inhibit trie metabolism of tuxom 
Duaeoam dosage may have to be decreased. 
Cimeodine: Cimettdme may inhibit the metabolism ot dia- 
zepam. Diazepam dosage may have to be decreased. 
Levodopa: Qartoam may decrease the therapeutic ettect.. 

fin^Sl Omeprazole may prolong the elimination ol 

fr-rancr Several studies have suggested an increased nsk 
01 congenital msllormations associated with the use ol dia- 
M am chlordiajeooxiae and meorobamate dunng me tins, 
truster ol pregnancy, tt the drug is ° rascllb f j ^.™ 
ol cn.ldbeanng potential, she should be warned to comae. He 
pnysician reading discontinuation ot the drug rt she intends 
to become cr suspects mat she is pregnant. 
U'won- Diazepam enters breast milk. It may accumulaie in 
the infant resulting in lethargy and loss o! weight. Use in 
lactation should be avoided. 

Genacriw: Elderly and debilitated patients or those with 
organic brain disorders have been found to be prone to CNb 
agression following even tow doses ol benzodiazepines. For 
mese patients me dosage should be limited to the smallest 
elective amount to preclude development ot ataxia, overseda- 
tion. falls or ottier possible adverse effects. 
Advtm Effects: CNS: Most of the adverse effects of dia. 
asam are due to Its depressant effect on the CNS. Ttiey 
af generally dose-dependent and include: drowsiness, ataxia, 
tegue. dizziness, vertgo. headache, slurred speech : memory 
Impairment, confusion, depression. Paradoxical CNS simu- 
lation may occur in early therapy. 
Gastrointestinal: nausea, hiccups. Increased appetite, ano- 
rexia weight gain or loss, dry mouth, increased salivation, 
swollen tongue, bitter or metallic taste, constipation. 
Genitourinary: menstrual irregulantres. failure to ovulate, j 
gynecomastia, increased or decreased libido, unnary retention 
or incontinence. 
Dermatologic: urticaria, rash, pruntus. photosensitivity may 

Oaffiutmologic: blurred vision, diplopia, nystagmus have 

Avascular: apnea, hypotension, bradycardia or cardiac 
arresl after rapid i.v. aaministrabon paniculariy in elderly or 
Militated patients and in patients with respiratory or cardio- 
vascular instability. 

Hematologic: rare cases ol leukopenia, agranulocytosis, 
aplastic anemia, hemolytic anemia, decreased hematocrit. 
Hepatic: elevation of liver enzymes has occurred and jaundice 
has also been reported. 

Ovsraose- Symptoms: Drowsiness, oversedation. contusion 
and slurred speech, In more senous overdosage, symptoms 
may include: hypotension, ataxia, hypotonia, hypnosis, coma 
and rarely death. When the effects of the drug overdosage 
ppgin to wear oft. the patient exhibits jitteriness and oversti- 
mulation There are minimum effects on respiration, pulse and 
bicod pressure unless the overdosage is extreme or mere is 
concomitant ingestion ol alcohol or other CNS depressant 
drugs. ( 

Treatment: In the case of an oral overdose, gastric 
lavage followed by the administration of activated cnarcoai 
may be beneficial if performed soon after ingestion, institute 
r-.neral supportive Iherapy as indicated. Vital signs and fluid 
balance should be carefully monitored. An adequate airway 
-nould be maintained and assisted respiration used as needed, 
fbmawnil antagonizes me CNS action of benzodiazepines and 
may be of value in the management ol overdose, rorced 
diuresis and hemodialysis are of no value. 
Dotage- Oral: Must be individualized and carefully btrated in 
orcer to avoid excessive sedation or mental and motor 



imomtwm A cuinutitive tncreasa ki the Ihcrapnulic eflrel 
dunng the first lew dart ol administration m.w be antiaoatcd. 
since drug sxemtton is slow. 

Oiazepam should neither be prescribed nor administered tor 
penods in excess ol 6 weeks, without follow up Bid csia- 
Uhsnmg the need lor more prolonged administration m mat- 
viilu.il patients. 

Abrupt discontinuation ol diirewm should bo avoided in 
patients wno have received long-term therapy. The drug 
snould be gradually tapered in order to avoid precipitation ol 
withdrawal symptoms or seizures in those patients with a [ 
history ol a seizure disorder. j 

tvmotomati: relief ol mild to moderate anxiety: Adults: i lo ; 
40 mg daily in divided doses, according to severity of symo- ; 
tcms and paueni response. Initiate treatment with low dose : 
and increase gradually. After dosage adjustment, the daily < 
dosage may be admimslcred in some patients in 2 divided . 
Poses or even in 1 dose, usually at night. 
Symptomatic relict ol acute alcohol withdrawal: Adults: 30 to 
JO mg in 3 or 4 divided doses dunng the first 24 hours, 
reducing the dose daily as indicated. 
As an adjunct for rei.et of spasm in pafients suffering from 
cerebral palsy, multiple sclerosis and athetosis: Adults: i to 
JO mg daily, in divided doses. 

Elderly and debilitated patients: 2.5 mg once or twice daily as 
tolerated. Initiate treatment always at me lowest dose and 
increase gradually as needed and tolerated. 
Children: 0.12 to 0.8 mcykg/day in 3 or 4 divided doses. 
Parenteral: The i.v. route Is preferable tor parenteral adminis- 
tration because i.m. absorption is erratic and unpredictable. 
The rate ol i v. administration should not exceed 5 mg/minute. 
Resuscitate resources should be available (see Warnings). 
In acute conditions, the injection may be repeated within 
! i hour although an interval of 3 to 4 hours is usually saosfac- 

°While dosage should Be individualized for maximum benefi- 
cial effect, the usual dosage is: 
Symptomatic relief ot mild to moderate anxiety: 2 to 10 mg 
I v. or i.m- Repeat in 3 to 4 hours, if necessary. 
Svmotomadc relief ol acute alcoholic withdrawal: 10 mg i.v. 
or I m initially, then 5 to 10 mg in 3 to 4 hours, If necessary. 
Premedicaoon for procedures: 5 to 10 mg i.m, or i.v. approxi- 
mately 30 minutes pnor to procedure. . 
As an adjunct tor relief of muscle spasm in patients suffering 
from cerebral palsy, multiple sclerosis and athetosis or tet- 
anus' 5 to 10 mg i.m. or i.v. initially, men repeated in 3 to 
i hours, ii necessary, for tetanus, larger doses may be 

required, , .,,„.♦„ 

Children: for station and muscle relaxation 0.04 to 
0.2 mg/Kg/dose every 2 to 4 hours i.v. or i.m. to a maximum 
of 6 rngAg in an 3 hour penod. 
Status eoiiepticus including severe recurrent seizures: In 
seiang patients, me i.v. mute Is preferable because pea 
plasma lev* may be reached only after 50 minutes ; when m 
i m route is used: 5 to 10 mg i.v. initially. If necessary to 
control secures, repeat at 15 n 30 minute 'nt^te far 
maximum ot 3 additional doses. Repeat m 2 to 4 hours I 
necessary Once seizures mod. begin aporopnate anticonvul- 
sant drug therapy immediately by the parenteral route. 
Children: For status epilepbcus 0.2 to 0.5 mo/kg/dose I v 
i repeat at 15 to 30 minute inter/ais for a maximum of 3 addi- 
| bonal doses. Maximum dose: > 5 year,: 10 mg. <5 years. 

i Cardioversion: To reiieve anxiety and tension: 5 to 15 mg i.v. 

i within 5 to 10 minutes prior to the procedure. 

\ Elderly and debilitated patients: (see Precautions and Adverse 

i Effects) 2 to 5 mg i.v. or i.m. 



DICETEL" Q 

Solvay King swooc! 
Pinaveriurn Bromide 



flewewed 1996 



DIBAN® © 

Wyetft-Ayerst: . „ 

Opi um -a»iiarinnna_Alka^idsCprnpo""d 

Antidiarrhea! 



Supplied: Each blue capsule with white ■ AYcRoT mono- 
gram contains: activated attacuigne 3C0 mg. pectin 71 i mg 
powders Odium 12 mg. hyoscyamine sullale 52 „,. atrop, 
Lllate 10 mQ. scopolamine HBr 2 „g. Energy: <l <J 
(< l vr.aij Bottles ol 12, 



G astraintc stinal Calcium Ant agonist 

FhaTmicultmy: Piuaver.um is a calcium anlMonist winch 
inhibits ine calcium influx by blocMnij the volMge-.Kioendiinl 
ciicium channel at the smooth nwsciii ceil invm. It onssesses 
j'ruqh degree ot selectivity lor the inlcstin.il smooth muscle. 
Many studies showed that pmaverium induces ,i relaxation 
ol the gastrointestinal and the biliary tracts and m.i.nly nl me 
colon an inhibition ol the motor colonic resoonsc to food and,' 
or pharmacological stimulations, implymc (he action ol the 
uruq in irnlable bowel syndrome. 
Indications- For the treatment and relief ot svmotcms associ- 
ated with irritable bowel svndrome (IBSI. abdominal pain, 
bowel disturbances and intestinal discomlorl. 

For the treatment of symptoms related to functional disor- 
ders ol the biliary tract. 

Conlraindicafions: Patients with known hypersensitivity to 
pmavenum or any ol me escioients. 

No other contraindications nave been identified at this time. 

Warnings: Contact ol pmavenum with the esophageal mucosa 

may be irritating. Therelore, it is strongiy recommended that 

the tablet be taken witn a glass ot water during mealtime. I 

! more lhan 3 tablets are prescribed pe' day, the additional 

i tablet(s) should be taken concurrently with a glass ol water 

\ and a snack. 

I Precautions: Pmavenum should not be administered lor the 
' relief ol motility dystunction due to unoertymg organic disease. 
Preonancr fleproducfive studies performed in animals have 
not revealed the presence ol teratogenic sheets. However, the 
saletv of pinaveriurn dunng pregnancy nas not been estab- 
lished Consequently, in the pregnant patient, this drug should 
only be administered if, in me judgment of the physician, its 
use is essential to the welfare ol Ihe patient. 
taxation- There have been no controlled studies in nursing 
women; therelore, the drug should be avoided dunng lacta- 
tion, 

Adverse Effects: Minor adverse events were reoorted and 
listed as mild and moderate, They were mainly mindr digestive 
disorders that may be related to the disease, such as epigas- 
tric pain and/or fullness (0.8%). nausea |0.5%>], consupa- 
tion «M%). heartburn {0.3%}. distension (0.3%) and 
diarrhea (0.2^). 

Other' Systems: headache (0.3%). dryness ol the mourn 
(0.3%). drowsiness (0.2%). vertigo (0.2%) and skin 
allergy (0.2%). 

Overdose: Symptoms and Treatment: In man, apart Irom 
diarrnea and/or flatulence, oinavenum mewed no undesirable 
effects in daily dosages ol uo to 1 200 mg. 

No cases ol overdosage ot pinavenum have been reports, 
to da" However, i! overdosage occurs, gastnc lavage is rec- 
ommended and symptomatic treatment initiated if deemed 
necessary. 

Dosage- The usual adult dosage is 3 lilm-coated tablets of 
50 mg a day tablet 3 limes a day), in exceptional cases, 
the dosage may be increased up to 6 tablets a cay (2 tablets 
3 limes a day). 

It 1S recommended that the tablet be taken with a glass ol 
water during meals or snacks. The taciet Should not be swal- 
lowed when in the lying oosdion or jus; before bedtime. ^ 

The duration of treatment depencs on the disorders -cr 
which pinaveriurn is given, 

Supplied: Each orange-coiored, circ-jla.'-s.iaoeS. lilm-coatsd 
tablet, wilh a slightly convex surlace. contain,: sinavenum 
bromide 50 mg. Nonmedical ingredients: m the co «. 
hydrophobic anhydrous smca. magnesium stearate, m.cK.- 
crvslalline cellulose, modified cornstarch, mcdiied lac.ose 
and talc- in the film coaling: gastr^oluble acrylic resin, 
microniKd talc, polyoxyetnyiene glycol 6000 and Sepispers 
oranre K3020 [titanium dioxide {£ 171), sunset yellow .axe 
(E 110) hydroxy propylcellulose (E iS3||: intermediary^- 
vents: acetone, ethanol and isoprcpanol Boxes of GO ■ _n 
blister packs. Store at room temperature (15 ,o uO C) m -s 
pensmg box. 

fSrtown in Proimci ftecograHQn Scaonj 

Renewed (995 



Cw-sn: '0 WiCwadM «.a«™<.™ircaMs: 



Ail u'.'^V-. f'W' 



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STATE OF MINNESOTA 
COUNTY OF RAMSEY 



1 " DISTRICT COURT 

SECOND JUDICIAL DISTRICT 

File No. C4-94-203 



vynnette Ann Hamanne, 
Kenneth Earl Hamanne, 
Adeana Ruth Hamanne, 



Plaintiffs, 



vs 



PARTIAL TRANSCRIPT 
OF PROCEEDINGS 



Diane Bay Humenansky, M.D., 

Defendant. 

The above- entitled matter came duly on for trial before 
the Honorable Bertrand Poritsky, judge;, of District Court, on 
the 30th day of June, 199S, in Room 1380 of the Ramsey , 
County 'Courthouse, in the City of St. Paul, State of 

Minnesota . 

RPPEARANCES : 

Edward Glennon, Esq., R. Christopher Barden, Esq. , and 
Christopher H. Yetka, Esq., appeared on behalf of Plaintiffs 
Vynnette Ann Hamanne, Kenneth Earl Hamanne, and Adeana Ruth 

Hamanne . 

David Waxman, Esq., and Eric Wein,' Esq., appeared on 

behalf of Defendant, Diane Bay Humenansky. 

********** 



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WITNESS INDEX 

JULY 24. 1995 



r 



CALLED TO TESTIFY ON 
BEHALF OF DEFENDANT 
REGARDING THE 

FRYE-DAUBERT ISSUES: 

PR, COLIN ROSS 

(Outside presence 

Examination - Mr. 

Examination - Mr. 

Examination - Mr. 

Examination - Mr. 

Examination - Mr . 

Examination - Mr. 



of jury) 

Waxman 

Barden 

Waxman 

Barden 

Waxman 

Barden 



CALLED TO TESTIFY ON 
BEHALF OF DEFENDANT: 



DR. 



COLIN ROSS 

(In presence of jury) 
Direct - Mr. Waxman 



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f.Tnl y 24. 19951 



(Aoorox. 1:30 p.m.?.. 



WHEREUPON, the following proceedings were duly had:' , 

(Appearances: As previously indicated, excluding 

Ms. Davy.) 

(The following proceedings were had in chambers. 

Robert Kuderer, Esq., also present in chambers.) 

THE COURT: The record should reflect the fact 
that I'm present in chambers with the three attorneys who 
appeared on behalf of the Plaintiffs in the Hamanne case and 
the two attorneys on behalf of the defense, Mr. Waxman and 

Mr. Wein. 

THE COURT: We've just briefly discussed 
scheduling. Mr. Kuderer now also showed up on behalf of the 
insurers. We've just discussed scheduling this afternoon. 
And at this point we've concluded that Mr. Glennon would 
like to make a statement for the record. He made an offer 
of proof -- not offer of proof, but he's outlined what he 
would say. I'd like to put that on the record now. If 
anybody wishes to respond, they may. 

MR. GLENNON: On Friday at one o'clock or 
thereabouts when we had a telephone conference with Ms. 
Lehr, who, as I understand it, is chief counsel for the 
Minnesota Court of Appeals, she was getting background 
information from the lawyers for the parties about the 
position -- each one's position -- with respect to the 



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until the end of October 1991 doing a combination of 
| inpatient and outpatient work, teaching and research. 
Q. What was the nature of your practice at the University of 
Manitoba? 

A. It evolved. It started off half time general adult 

\^ . 

inpatient work, which means basically people coming through 

the emergency department with all kinds of different 
psychiatric diagnoses, and receiving acute care. And half 
time director of the anxiety disorders clinic. 

Then in 1988 I stopped the anxiety disorders clinic 
half and started a dissociative disorders clinic. And 
basically followed that pattern until the last nine months 
before I left in late '91, I did solely outpatient 
dissociative disorders work, which included clinical 
service, teaching, research. 
Q. What was the nature of your research at the University of 
Manitoba? 

A. There's several different types of research I did inside the 
dissociative_ disorders field and outside the dissociative 
disorders field, both. I had a number -- this is all 
reflected in my C.V. I did a number of drug company 
contracts, which means there is a drug that isn't yet on the 
market that a drug company is developing, and in the United 
States the Federal Drug Administration, in Canada the Health 
Protector Branch, mandates by law that there is a large 



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1 number of different studies with placebos have to be done i n 

2 various university settings across the country before the 

3 drug can be approved to go on the market. I was involved in 

4 trials of that sort with anti-anxiety drugs, ant i -psychotic 

5 drugs, antidepressant drugs. 

S Then I did several pieces of research having to do with 

7 the teaching and training of psychiatry residents to perform 

8 various psychiatric functions in a reliable fashion. Some 

9 research on criteria for collect selecting resident and 

10 whether they're reliable and have any validity. 

11 Q. You are familiar with the scientific concepts of validity 

12 and reliability? 

13 A. I am. V. 

14 Q. Please proceed. 

15 A. Then I did what's called epidemiological research in the 

16 general population and in the clinical population. This 

17 means using various kinds of standard measures to survey 

18 either the general population or various types of people in 

19 treatment, grouping of people in treatment, to see how 

20 common dissociative symptoms and dissociative disorders are 

21 in those various groups. And a variety of studies basically 

22 focused on trying to differentiate multiple personality 

23 disorders from other psychiatric disorders. Studies looking 

24 at what is the other forms of mental health problems that gp 

25 along with multiple personality disorder. Usually it 



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suburbs of Dallas. Richardson is where my private office 



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is, and Piano is where the hospital I practice is. 

q. It doesn't sound like a Texas accent. Where were you born 
and raised? 

A. Just a little north of the Texas border in Canada. 

Q. Okay. Where was it that you were educated, Sir? 

A. I did my medical school work in Edmonton at the University 
of Alberta. I got my M.D. degree in 1981. Then I moved to 
Winnipeg and did my psychiatry training. Got my Canadian 
certification in psychiatry as a specialist in 1985. 

q. After you finished your training in 1985, did you engage in 
the practice of psychiatry? 

A. The academic year ends at the end of June. I finished my \ 
training at the end of June. Beginning of July of '85 I 
became what is called an assistant and later associate 
professor of psychiatry. I split my time basically in terms 
of the clinical part between general adult inpatient 
psychiatry, which means people come in through the emergency 
department with any kind of psychiatric disorder, and half 
time in an anxiety disorders clinic. Then I did teaching 
and research and academic work. 

Q. And in what areas did you do teaching, research, and 
academic work? 

A. I did a smattering of research and teaching in quite a few ^ 
different areas of psychiatry. What is called drug studies, 



as 



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where the drug company has some new medication that they're 
developing that's not on the market yet, and they need a lot 
of studies comparing the drug to placebo in a lot of 
different cities before it can get approved to be on the 
market. I took part in those type of studies and published 

some of those . 

Different kinds of research having to do with 
teaching residents to perform what is called a mental status 
examination, which is asking about the person's mental state 
in a very systematic way, and figuring out a way to teach 
residents reliably so they can do that accurately. Studies 
about criteria for selecting residents into specialty 
training in medicine. A hodgepodge of other studies having 
to do with clinical signs and symptoms and different 
disorders. Most of it was focused on what's called the 
dissociative disorders. 

What are included in dissociative disorders? Obviously, 
we'll get into more detail later, but generally. 
Well, the. psychiatric system is in a diagnostic manual 
that's put out by the American Psychiatric Association 
called the Diagnostic and Statistical Manual . The first 
edition came out in 1952. It keeps going through updated 
editions. The last one was updated in 1994. 
Is that what you refer to as DSM? 
Yes DSM, Diagnostic: and S tatistic al Manual , and IV is the 



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112_ 

or half -day workshops, then there's people who submit 
research papers. Usually you have 15 or 20 minutes to 
present some piece of research or some clinical insight that 
you have. Most of these are at various meetings and 
workshops and so on. 
Okay. As of October '93, you had submitted 41 such papers, 

correct? 

Right . 

And I take it that number might be a little higher now? 

Right . 

Your C.V. also indicates awards that you have won and grants 

that you have received, correct? 

Correct . V 

Anything in particular that you would comment on there? 
Well, under grants received, you can see there's a lot of ■ 
different drug studies there. There's money from faculty of 
medicine at the University of Alberta. There's money from 
faculty of medicine at the University of Manitoba. There's 
several different research foundations in Canada, National 
Research Foundation, several different research funds. And 
quite a wide variety on topics mostly focused on 
dissociative disorders. There's a lot of different people, 
a lot of different grant agencies that have decided my 
research is worth funding. «■■ 

-ft 

And below that section, there is a list of contracts that 



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1 you've had with various drugs companies, which again is a 

2 continuation of the work that you were describing earlier? 

3 A. Right. 

4 Q. And, Doctor, you also have professional activities listed? 

5 A. Right. 

6 Q. These are other organizations and/or journals that you have 

7 an association with? 

8 A. Correct. 

9 Q. And if we can turn to Page 21, items 34 through 40, you are 

10 a reviewer 'for various journals, is that correct? 

11 A. Yeah. There's probably four or five more that are on the 

12 updated C.V. This basically means that, say the Journal of 

13 Biological Psychiatry , somebody submits a paper to that 

14 journal, it's then sent out to me and anywhere from one or 

15 two or three or other reviewers to give an opinion as to 

16 should it be published or not published. If it should be 

17 published, what revisions are required, what are the 

18 problems, what needs to be tidied up? In other words, these 

19 journals seek me out to give an opinion on what they should 

20 publish. 

21 Q. You are requested by the journals to review various pieces 

22 of literature? 

23 A. Yes. 

24 Q. You were so requested by the American Journal of Psychiatry? 

25 A. Correct. 



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The Journal of. Clinical Psychiatry ? 



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The Canadian Journal of Psychiatry? 



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Right . 

Among others? 

Right . 

Any others that you would list for the jury at this time? 

Psychological Reports , Hospital and Community Psychiatry , 

Psychiatry . There's probably one or two more. I can't 

think of them now. 

Obviously, 37, the specialty journal Dissociation, you 

reviewed for that as well? 

Right . V ■■ 

Doctor, are there any other positions, in addition to your 

reviewing, that you wish to discuss at this time? 

Well, I've also reviewed similarly for a number of different 

grant agencies, five or six different grant agencies. They 

send me now a grant application. I'm giving an opinion 

should this research be funded or not. 

The research is scientific work that's being proposed by 

various other professionals? 

I've reviewed grants on a fair range of topics: Anxiety 

disorders, dissociative disorders, cognitive therapy, 

borderline personality disorder, and childhood trauma. 

The agencies or entities with the purse strings have 



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1 requested you to comment on what other scientists have 

2 proposed? 

3 A. Right. 

4 Q. Then there's a vast number of workshops that you have given? 

5 MR. BARDEN: Objection to "vast number', " Your 

6 Honor . 

7 BY MR- WAXMAN: 

8 Q. Okay. Ninety-nine workshops, through Page 28, is that 

9 correct? 

10 A. Correct. 

11 Q. Whether 99 is vast or not -- 

12 THE COURT: Well, let me overrule the objection. 

13 The answer stands. Go ahead, Mr. Waxman. 

14 BY MR. WAXMAN: 

15 Q. Has that number increased in the last two years? 

16 A. There would probably be another 15 to 20. 

17 Q. Okay. And without going through these individually, can you 

18 briefly tell the jury the types of workshops that you have 

19 presented the 115 or 120 or so? 

20 A. It's basically all kinds of workshops all over Canada and 

21 the United States, mostly on multiple personality disorder, 

22 dissociative disorders, varying from one hour to two full 

23 days; two full days of just me, I mean. 

24 Q. Doctor, is there anything else about your background and 

25 experience that is contained in your Curriculum Vitae you 



STATUTORY DECLARATION of Anne Mary Lambert and William 
Edmound Lambert 

Made this / day of June, A.D., 1996 



Anne & Bill Lambert 

Box 239 

Shoal Lake MB. ROJ 120 

Tel: 204- 759-2207 



STATUTORY DECLARATION 

We, Anne Mary Lambert and William Edmound Lambert, are married and reside at 
the Town of Shoal Lake in the Province of Manitoba, do solemnly declare: 

1. That our married daughter Marcie Marjorie Harrison(nee Lambert) at the age of 
twenty-eight(28) years of age, commenced a course of therapeutic counseling at the 
Hamiota Health Centre, in the Province of Manitoba in April 1992, under the care of one 
Teresa Pelland an employee of the Hamiota Health Centre, and 

2. That after approximately one week of therapeutic counseling sessions with Teresa 
Pelland at the Hamiota Health Centre, we beleive that our daughter Marcie Marjorie 
Harrison(nee Lambert) as the result of fraudulent therapy, developed false implanted 
memories of having been sexually abused by her father William Edmound Lambert in 
her(Marcie's) childhood, and 

3. That our daughter was the subject of additional counseling in 1992 and 1993, under the 
care of therapist one David Reed at the City of Brandon, and who(David Reed) we 
believe practiced a fraudulent form of memory recovery/multiple personality 
disorder(MPD) diagnostic therapy that was first developed by Dr. Colin A. Ross in 1985 
at the City of Winnipeg in the Province of Manitoba, and 



4. That the fraudulent false memory recovery therapy introduced into Manitoba in 1985, 
by Dr, Colin A. Ross and which therapy we believe was practiced by Teresa Pelland, at 
the Town of Hamiota and David Reed at City of Brandon, has devastated our family 
relationships and we will seek whatever relief that is available, and 

That we make this solemn declaration conscientiously believing it to be true, and 
knowing that it is of the same force and effect as if made under oath. 



Declared before me at the Declarants: 

City of Winnipeg, in the Province Anne Mary Lambert 

of Manitoba, this / — day \ X r\t^ju '-£. (jlhiW^ 

of I^jl ,ATU1996 n 

;&ge Bergen ££^^ ( *S_^*a~ S William Edmpund Lambert 



Getfrge Bergem ^>^^-, / ^,»^ 

Commissioner of Oath in and for the 
Province of Manitoba. My Commission 
expires on March 26, 1998. 



STATUTORY DECLARATION of Margaret Juce and Michael Juce 

Made this 4- day of July, 1996 



Margaret Juce & 

Michael Juce 

Box. 243 

Warren, MB. ROC 3E0 

tel: 204-322-5388 



STATUTORY DECLARATION 

We, Margaret Juce and Michael Juce, reside near the Town of Warren, in the Province of 
Manitoba, do solemnly declare: 

1 . That our married daughter at about thirty-three(33) years of age, commenced a course of 
therapeutic counseling at the Sherbrook Counselling Services, in the City of Winnipeg, in or 
about 1988 under the care of one Judy Hill, a practising therapist associated with or employed by 
the Sherbrook Counselling Services, and 

2. That, after commencing therapeutic counselling under the care of Judy Hill, our daughter 
began to believe that she had been sexually abused during her childhood, and 

3. That, as counselling progressed, we believe that as a result of fraudulent therapy practiced by 
Judy Hill, our daughter developed false childhood memories of having been sexually abused by 
her mother(Margaret Juce), and 

3. That the fraudulent false memory recovery therapy introduced into Manitoba by one Dr. Colin 
A. Ross in 1985, and which therapy we believe was practiced by Judy Hill at the Sherbrook 
Counselling Services, has been devastating to our family since and we will seek whatever relief 
that is available, and 

That we make this solemn declaration believing it to be true, and knowing that it is of the same 
force and effect as if made under oath. 



Declared before me at the 

City of Winnipeg, in the Province Declarants : 

of Manitoba, this tf-^ day , Margaret Juce 




*hn„s, ^A ,£> .Quxju 



Commissioner of Oath in and for the Michael Juce 

Province of Manitoba. My Commission 
expires on March 26, 1998. 




STATUTORY DECLARATION of Use Babletek 



made this 9 ^ day of L**4 A.D., 1996 



Use Babletek 

19 Tracy Crescent 

Winnipeg, MB. R3M 4H5 

Tel: 204-253-0232 



STATUTORY DECLARATION 

I, Use Babletek, at the City of Winnipeg, in the Province of Manitoba, do solemnly 
declare: (i- . 

1. That in 1992, my married daughter at the age of thirty- ttneee(37) years commenced a 
course of therapeutic counseling at the offices of one Dr. Lynn Ryan in the City of 
Winnipeg, and 

2. That after having attended therapeutic counseling at the offices of Dr. Lynn Ryan, my 
daughter developed falsely induced memories of having been sexually abused by her 
father Jenoe Babletek. and 

3. That in 1993, my daughter confronted and falsely accused her father Jenoe Babletek of 
having sexually abused her(my daughter), in her childhood, something that never 
happened. 

4. That, I believe my daughter developed these false memories as a result of fraudulent 
therapy that she received at the offices of Dr. Lynn Ryan, a form of false memory 
recovery therapy that I have been told was first introduced into Manitoba by Dr. Colin A. 
Ross, and 

5. That this false memory recovery therapy has devastated our family and I will seek 
whatever relief that is available to me, and 

That I make this solemn declaration conscientiously believing it to be true and having the 
same force and effect as if it were made under oath. 



Declared before me at the 
City of Winnipeg, in the Province 
of Manitoba, this .% -C> day 
of 



George Bergen /y 



: A.D. 199% 



^ P- ■ Declarant: 

me- 

■QsK"Babletek 



^n 



L2<^ 



M^iAJl^/ 



Commissioner of Oath in and for the 
Province of Manitoba. My Commission 
expires on March 26, 1998. 



STATUTORY DECLARATION of George Bergen 

made this f^L day of >xXi^ , A.D., 1996 



George Bergen 
150 Dorge Drive 
Winnipeg, MB. R3V 1M4 

Tel:204-261-4382(home) 
. 204-982-6432(office) 



STATUTORY DECLARATION 

I, George Bergen, at the City of Winnipeg at the Province of Manitoba do solemnly 
declare: 

1 . That the statements contained herein, and which statement I believe to be true, were 
told to me(George Bergen) by Peter Wrublowsky who resides with his wife Mary at: 

1061 Betournay Street 
Winnipeg, MB. R2 J 1E2 

Tel: 204-253-0680, and 

2. That I, George Bergen, was advised by Peter Wrublowsky, that his daughter 
commenced a course of therapeutic counseling at the Family Centre of Winnipeg in 
1 990, under the care of Elaine Bergen and Sara Axelrod, who were employed or 
associated with the Family Centre, and 

3. That as a result of therapy at the Family Centre, Peter and Mary Wrublowsky' s 
daughter developed false memories of having been sexually abused by her father, and in 
1991 the daughter confronted Peter Wrublowsky with false allegations of having been 
sexually abused, and 

4. That I, George Bergen, believe that Elaine Bergen and Sara Axelrod were practicing 
fraudulent false memory recovery therapy, similar to the form of fraudulent therapy 
introduced into Manitoba by Dr, Colin A. Ross in 1985, causing great harm to the 
Wrublowsky family, and 

That I make this solemn declaration conscientiously believing it to be true and having the 
same force and effect as if made under oath. 



Declared before me at the 
City Of Winnipeg, in the Province 
of Manitoba, this ^// day 
of (JmUf A.D., 1996. 

Jan Malanowich \/f(Xn^ '~)llr/J'.&^<J^<S/ CA-^ 
Commissioner ofrOaths in and for the 
Province of Manitoba. My Commission 
expires on {QsL*4.fA/ / , 1997. 




y • George Bergen 



STATUTORY DECLARATION of George Bergen 

made this #)& day of }Ltc^^ A.D., 1996 



r 



George Bergen 
150 Dorge Drive 
Winnipeg, MB. R3V 1M4 

Tel: 204- 261- 4382(home) 
204-982-6432(office) 



STATUTORY DECLARATION 

1. George Bergen, of the City of Winnipeg in the Province Of Manitoba do hereby 
solemnly declare: 

{. That my spouse Bonnie(Joan) Bergen began a course of therapeutic counseling in April 
1992, under the care of one Tammy Schultz employed by or associated with the 
Winnipeg Christian Counseling Group, an agency of the Grant Memorial Baptist Church, 
at the City of Winnipeg in the Province of Manitoba, and 

2. That after two(2) counseling sessions, Tammy Schultz advised Bonnie Bergen that 
she(Bonnie) had all of the signs of having been sexually abused as a child even though 
Bonnie had no memory of this abuse, and 

3. That as counseling progressed, Tammy Schultz advised Bonnie that she(Bonnie) had 
all of the signs of having been abused by a satanic cult thoughout her childhood years, 
and 

4. That Tammy Schultz provided Bonnie Bergen with satanic cult literature that Schultz 
may have obtained as a member of the Manitoba Government's nineteen member satanic 
search and education committee, and 

5. That Tammy Schultz often reassured Bonnie Bergen that everything about 
her(Schultz's) therapy was legitimate because it was government approved and that 
she(SchuItz) was on a Government committee that had the police and clergy 
representation on it, and 

6. That Tammy Schultz diagnosed Bonnie as having multiple personality disorder(MPD). 

7. That in November, 1992 Bonnie Bergen became mentally ill and she(Bonnie) began to 
have failing memory and she could no longer differentiate between suggestions made to 
her(Bonnie) and reality, and 

8. That Bonnie's personal physician Dr. Debra Wiens at the St. James Medical Clinic 
agreed with Tammy Schultz' s assessment that Bonnie had MPD, and she( Wiens) would 
frequently ask Bonnie "who am I talking to now" or "which one am I talking to", when 
Bonnie made her visits to her(Dr. Debra Wiens), and 

9. That when pastor Bob Carroll and deacon Ewin Dirks leaders of the Fort Richmond 
Baptist Church(Bonnie's home church) were appraised of Bonnie's therapy in January 
1993 and her husbands(George Bergen's) objection to Schultz's therapy as being "lies 
and falsehoods", Carroll and Dirks made every effort to protect Schultz and advised that 
Bonnie's satanic ritual abuse in childhood was "possibly all true", and 



10. That in April 1993, Tammy Schultz and Dr. Debra Wiens arranged for Bonnie to go 
for a psychiatric assessment at the St. Boniface Hospital, where Dr. Stewart Wakeman 
diagnosed Bonnie as having MPD, and 

1 1. That in September 1994, Bonnie Bergen realized that Tammy Schultz had implanted 
false memories in her(Bonnie's) mind whereupon the Bergen family filed a civil suit 
against Tammy Schultz and the Grant Memorial Baptist Church, and 

12. That in January 1995, Bonnie Bergen was assessed by Dr. Harold Merskey in London 
Ontario, who diagnosed Bonnie Bergen as not having MPD, and 

13. That from 1992 to 1995, as a result of the fraudulent false memory recovery /MPD 
therapy, practiced by Tammy Schultz, Bonnie's condition had deteriorated to the extent 
where she could no longer function as a mother or a homemaker, and 

14. That in 1995, total disability pensions under the Civil Service Superannuation Fund 
and the Canada Pension Plan where approved for Bonnie Bergen, and 

1 5. That the false memory recovery/MPD therapy practiced by Tammy Schultz, and 
which therapy was first introduced into Manitoba by one Dr. Colin A. Ross in 1985, has 
devastated our family and I will seek whatever relief that is available to me, and 

That I make this solemn declaration conscientiously believing it to be true and having the 
same force and effect as if made under oath. 



Declared before me at the 

City of Winnipeg, in the Province Declarant 

Manitoba^this ^^Aj day 

of (A-cAa^ ,A.D. 1996 




Jan Malanowich K^p^^O^^^^^^-c^/ C -A-- 
Commissioner owJath in and for the 
Province of Manitoba. My Commission 
expires on $^Lsby^JLsts / 1 997. 




STATUTORY DECLARATION of George Bergen 

made this j^d day of )Ll1u^ , A.D., 1996 



George Bergen 
150 Dorge Drive 
Winnipeg, MB. R3V 1M4 

Tel:204-261-4382(home) 
204-982-6432(office) 



STATUTORY DECLARATION 



I, George Bergen, at the City of Winnipeg in the Province of Manitoba do solemnly 
declare: 

1. That the statement which follows hereto and which is marked as Exhibit #200, and 
which statement I believe to be true, was written by Shiela and James Shoesmith, who 
reside at: 

Apartment 525 
135 Niakwa Road 
Winnipeg, MB. R2M 5K2 

Tel: 204-257-9444 

2. That I, George Bergen was advised by Shiela and James Shoesmith that one Shar 
Reid, M.Ed., M.S.W., at the City of Winnipeg, a therapeutic counselor, was responsible 
for implanting false memories into the minds of the Shoesmith's daughter, and 

That I make this solemn declaration conscientiously believing it to be true and having the 
same force and effect as if made under oath. 



Declared before me at the 
City of Winnipeg, in the Province 
of Manitoba, this <?H^ day 
o f(Wy .A.D., 1996 

Jan Malanowich \J ! ^^ y ^/y7^<^^<^^<^ / C/ C 
Commissioner ^f/Oaths in and for the 
Province of Manitoba. My Commission 
expires on (Q/Jj-^-^/ /. 1997. 




£^U^^ 



&£ Oo 



We are a family experiencing the devastating effects of False Memory Syndrome. 
My husband and [ have been married for forty years. We have a son and a daughter. 
Our daughter is the oldest. Shortly after her thirtieth birthday in January, 1989, she began 
seeing a therapist. The therapist's name was Shar Reid, M.Ed., M.S.VV. She was a member 
of Associated Marriage and Famiiy Therapists in Winnipeg. 

We were not surprised at her seeing someone for her depression, although we did feel 
she should go to a psychiatrist. She had suffered with bouts of depression since age eighteen. 
After two months in therapy she stated she wanted nothing to do with us and wrote us 
a letter saying she thought she may have been sexually abused as a child. After reading the 
shocking letter, we contacted her and asked to see her and her husband immediately. She 
declined, saying that I, and not her father, could go to the therapist with her. At that meeting, 
which was being tape-recorded, Ms. Reid, the therapist, told me that our daughter had been 
sexually abused by her father when she was two years old. When I had questioned our 
daughter she had been very vague- not knowing who the perpetrator was and not sure how 
old she was at the time, etc. 

I was, to say the least, in shock at all this. I told her and the therapist that I knew for 
sure it was not her father and if, in fact, it ever happened, which I doubt to this day, it must 
have been a baby-sitter or neighbour. 

When the hour was over we arranged another appointment for the following week. 
The next day I went to see my family Doctor and told him everything. He advised me 
not to meet with them again as he felt Ms. Reid did not have the proper education and 
training to handle this type of situation. He suggested I ask our daughter to go to a 
psychiatrist with me and that he would set up an appointment with one. When I approached 
our daughter with this suggestion she turned me down. She wanted nothing more to do with 
us. We were devastated. 

She also wrote a letter to our son asking him to meet her and discuss their childhood. 
He refused, saying there was nothing wrong with their childhood. He is supportive of us and 
has not seen or heard from her in over five years either. 




#7.0 



When all this happened to us over five years ago we had no idea it was happening in 
other families as well. Finally in September, 1992, we saw a television program about False 
Memory Syndrome with the telephone number of the Foundation in Philadelphia, and we got 
in touch with them, 

We are also members of the False Memory Syndrome (Manitoba) support group and 
have met many wonderful people who have lost their daughters to therapy. 

With there being no licensing of therapists in Manitoba, there is nowhere we can 
complain and we feel there should be a governing body so that there would be more control 
over the therapeutic community and also access for our concerns. 



STATUTORY DECLARATION of George Bergen 

made this 3/jL> day of Htl ZcV A.D., 1996 




George Bergen 
150 Dorge Drive 
Winnipeg, MB. R3V 1M4 

Tel:204-261-4382(home) 
204-982-6432(office) 



STATUTORY DECLARATION 



I, George Bergen, at the City of Winnipeg in the Province of Manitoba do solemnly 
declare: 

1, That the statement which follows hereto and which is marked as Exhibit #300, and 
which statement I believe to be true, was written by Hilda Gushsulak, who resides at: 

St. Rose du Lac, Box 209 
Manitoba, ROL ISO 

Tel: 204-447-2463, and 

2. That I, George Bergen was advised by Hilda Gushulak that one Ken Barkman 
associated with the St, Boniface Hospital, at the City of Winnipeg, a therapeutic 
counselor, was responsible for implanting false memories into the minds of the 
Gushulak' s daughter, and 

That I make this solemn declaration conscientiously believing it to be true and having the 
same force and effect as if made under oath. 



Declared before me at the 
City of Winnipeg, in the Province 
of Manitoba, this ftis day 
ofiLjUJ , AIL 1996 

Jan Malano wich \ Ja~* . 7 y)^y^^-<x^ / ° ^ 
Commissioner of Oaths in and for the 
Province of Manitoba. My Commission 
expires on (0s,Ln-4iS / L> > ^7. 



Declarant: 



7 ^~~y4- 



/George Berger 



's&~*T & j£~-~^ 



1 300 

Our eldest daughter was diagnosed with a genetic disorder when she was 14 years old. 
This caused her to grow very tall and to have cardiovascular problems, all a part of the same 

condition. 

She wanted nothing more than to be the same as her peers, and would never accept 
that nothing would be normal for her but she could still live n full and productive life within 

the limits set by her doctors. 

All of our attempts to help her deal with her ailment were rejected. She did not want 
to see any psychologist or psychiatrist for help in healing the mental and emotional trauma 
caused by this diagnosis. Then commenced the waiting for the right time for open-heart 
surgery, which she had done when she was 28. We almost lost her- the aneurysm ruptured in 
the O.R. Then ensued the long, slow, and painful convalescence. 

Ail the time, of course, we were there for her, during her iimess and her good periods, 
and were very proud that she did accomplish much in spite of her physical condition. We 
were very close and the very best of fnends. All has now changed. 

She started therapy, juiL before her surgery, for weight cuntroi. She changed 
therapists- we are not sure why. Roth therapists were female, but she stayed with the second 
for a very short time. She then started seeing a maJe social worker/hypnotist/massage 
therapist... whatever else he purports to be Following is a litany of events since she has been 

with him: 

I- Progressive alienation, coldness, hostility, rudeness, belligerence, so different from 

the warm, friendly, compassionate girl we all knew. 

II- In February 1992 our daughter came home to tell us she wanted no more contact 
with us and that she would inform us when we couid see her again. 

Ill- In November 1992 we received the first of four letters from her asking about 
possible abuse and abusers when she was a child- the letters became more strident, more 
desperate sounding, more distraught. 

IV- Letter #4 came January, 1993, the vilest, most venomous missive. Here are the 

main points. She accuses us of: 

1. Gross ritualistic sexual abuse by both parents, both sets of grandparents, 
aunts and uncles on both sides, all our friends and most of the town. All kinds of abuse- 
physical, mental, emotional, sexual, ritualistic. 




^3 ^ ° 



2. Burning children at stakes and other sacrifices in pits, with altars and fires. 

3. Making pornographic pictures and movies with her in the starring role, 

4. Forcing her into child prostitution. 

5. The abuse started the moment she was bom, she says. 

She has made many other allegations and accusations but the real cruncher is this: 
there will be no reconciliation until we admit to all this stuff and nonsense. There is not a 
smidgen, not an iota of truth in any of her statements- this is all so bizarre! It is also painful . 
And it all started when she began seeing her present therapist, who also wilt not acknowledge 
our existence and will not see us. 

I must tell you how very unhealthy is her relationship with this person. She sees him 
three times per week plus she phones him almost every day, sometimes more often. As you 
probably know, a patient needs time to process one session before going into another- seeing 
this man so often does nothing except compound all these fallacies. 

She apparently also has been diagnosed as having "multiple personality disorder". 
Whose diagnosis is this? This is a psychiatric condition... a social worker is most unqualified 
to diagnose. 

I would like now to list some of the techniques he uses for memory enhancement that 
are so intrusive, and very, very harmful: 

I- Hypnosis- Our daughter has been hypnotized several times. We think that 
she is in a post-hypnotic trance and her mind is being controlled by her therapist. 

II- Contracting with the individual alters (multiple personalities)- Wrong, 
wrong, wrong!! The point of therapy is to integrate, not to segregate the alter egos. 

III- Guided Imagery- Think about it. Are these patients really to imagine 
happenings under the direction of the therapist, who doesn't know any of the extended family 
and therefore cannot possibly make any kind of fair and informed judgement? 

IV- Massage therapy- Hogwash!! memory is not stored in the tissues. There 
is not a single, solitary calf muscle that can remember how or when it was rubbed or for what 
reason. This therapist has aiso manipulated the genitalia of our daughter and she has 
manifested bruises on the inside of her thighs, supposedly done during massage therapy. 



%*M^* 3 ° 



6 



V- Drug therapy- We are not sure if she lias ever been given sodium amytal. 
We certainly hope not. A social worker is not qualified to give any kind of medication. She 
is also on medication for her heart condition which should probably not be mixed with a 
barbiturate. 

This is only a bare outline of what has befallen our lovely girl- there are a myriad of 
other details too numerous to mention. But 1 do have to teil you that we are appalled at the 
kind of person she has become, through no fault of ours or hers. This therapist is evil 
personified. He has made our daughter become mentally ill and is causing so much pain, 
unhappiness and distress, not only for us but also for her. She has shed rivers of tears and 
we have felt each drop. He is depriving her of the love , comfort, and support of the people 
who care for her the most. 



STATUTORY DECLARATION of George Bergen 

made this tffii day of )juM^ , A.D., 1996 



George Bergen 
150 Dorge Drive 
Winnipeg, MB. R3V 1M4 

Tel:204-261-4382(home) 
204-982-6432(office) 



STATUTORY DECLARATION 



I, George Bergen, at the City of Winnipeg in the Province of Manitoba do solemnly 
declare: 

1. That the statement which follows hereto and which is marked as Exhibit #400, and 
which statement I believe to be true, was written by Connie Pilgrim, who resides at: 

904-100 Adamar Road 
Winnipeg, MB. R3T 3X6 

Tel: 204- 261-4225 

2. That I, George Bergen was advised by Connie Pilgrim that one Dr. David Bolton, at 
the City of Winnipeg, a Psychiatrist, was responsible for implanting false memories into 
the minds of the Connie Pilgrim's daughter, and 

That I make this solemn declaration conscientiously believing it to be true and having the 
same force and effect as if made under oath. 



Declared before me at the 

City of Winnipeg, in the Province Declarant: 

ofManitoba, this %/& day 4^ 

o Lh/JU .A.D., 1996 /£t^* 

fj ' / 7 /ueorge Q€r|en 

Jan Malanowich )/^m TT^^^o^-g-c// C^ ^ 
Commissioner of Oaths in and for the 
Province ofManitoba. My Commission 
expires on jL^iC^JAf,.,/ > !997. 




■*f, 



^^LJ^t "I** 



Another Mothers' Day has just passed - the fifth one without a word from my 
daughter. 

Five years ago, my daughter went to see a psychiatrist, seeking help and understanding 
of the general stress of mid-life challenges. During the course of her visits, he asked her if 
"she ever thought she might have been sexually abused". She said "No", and asked me about 
it. I was stunned to think anyone would suggest such a possibility. 

However, she took this suggestion to a therapist, who picked up on it and took her 
into a feminist self-help group. This group suggested reading such books as The Right to 
Innocence, and The Courage to Heal , ... the latter formulates the program for recovery for 
"victims". It recommends that one divorce one's natural family, and break with anyone who 
does not agree with the victim. My daughter has followed these precepts to the letter. Her 
rage and language on the telephone when last we talked was horrible. She has divorced her 
parents, sisters, brother, nieces and nephews, in fact anyone who had formerly been close to 
her. To think that at one time she had been part of a warm, loving family, and we all live in 
Winnipeg. None of my other children believe her, and they were all brought up in the same 
family environment. To date, no corroborative evidence for her claims has been established. 

Neither the psychiatrist nor the therapist will see or speak to me. Part of this whole 
problem is that anyone can call herself or himself a "therapist". There are no special 
qualifications for the job, no diploma, no license , no regulating committee to defer to. Not 
all, but certainly some therapists are not qualified, and as a result are doing harm, and should 
be held accountable. 



STATUTORY DECLARATION 

I, George Bergen, at the City of Winnipeg at the Province of Manitoba do solemnly 
declare: 

1. That the statements contained herein, and which statement I believe to be true, were 
told to me(George Bergen) by Robert Baker who resides at: 

185 Dalhousie Drive 
Winnipeg, MB. 4T3 2Y9 

Tel: 204-269-9636 

2. That I, George Bergen, was advised by Robert Baker that his daughter commenced a 
course of therapeutic counseling at the St. Boniface Hospital in the City of Winnipeg in 
1993 at the daughter's then age of eighteen, and 

3. That as a result of therapy at the St. Boniface Hospital, Robert Baker's daughter 
developed false memories of having been sexually abused and raped by her father Robert 
Baker, and 

4. That Robert Baker further advised me(George Bergen) that he(Robert Baker) was 
charged with incest and sexual assault in 1994, and that it cost him ninety thousand 
(590,000. 00)dollars in legal fees to prove his innocence as per the attached newspaper 
articles identified as Exhibit #1000, and 

5. That I, George Bergen believe that the St. Boniface Hospital used the same or similar 
fraudulent false memory recovery/MPD therapy that was introduced into Manitoba by Dr. 
Colin A. Ross in 1985, and 

That I make this solemn declaration conscientiously believing it to be true and having the 
same force and effect as if made under oath. 



Declared before me at the 

City Of Winnipeg, in the Province Declarant 

of Manitoba, this %Mj day 

of (^y^/ ,AJ)„ 1996. 



rh / 



( n 



Jan Malanowich ^M^n W^^-> I ^ L, ^ // 



c£> 




Commissioner o^£)aths in and for the 
Province of Manitoba. My Commission 
expires on fi jjL*&jf*. / , 1997. 



^U+^J ^ J££ZL 




Incest ruled 



9 



memory 

Teen shocked as judge rejects testimony as 'product of her mind' 



Sy Kevin Rollason 
Ls:v Courts Reporter 



A JUDGE dismissed a teenag- 
er's incest testimony yester- 
day as a produce of false 
memory syndrome, the first time a 
Manitoba court has recognized the 
syndrome's existence. 
'"I think she honestly believes it 
happened to her," Mr. Justice Ken- 
neth Hanssen of Court of Queen's 
Bench said while acquitting the 
teenager's father of incest and sex- 
ual assault charses. 



But he said he had to go beyond'- 
simolv finding the man not guilty. 

"That person can srili suffer a 
stigma in the community. The public 
assumes the person was guilty, but 
got off because of the judge's rea- 
sonable doubt. 

"My view is the alleged assaults 
probably never occurred and were, 
really the product o f (her) mind." _ 

A 19-year-old woman had testified 
her father' sexually jissaulted__ her 



about eight time's while "she'was 15. 
She claimed she suppressed the 
memories until she experienced a 
flashback after receiving therapy at 
the Health Sciences 'Centre, and 
later St. Boniface General Hospital,- 
for depression. 

But she also testified she had the 
flashback about a week after being 
questioned by a nurse about 
whether she'd been sexually abused 
by her father. ■ 

And the teenager - who claims 
her father is the only sex partner 
she's ever had - refused a medical 
examination. 

With tears rolling down her 
cheeks outside the courtroom, she 
s<dd although she didn't want her fa- 
ther to go to jail, she couldn't believe 
what the judge said. 

"He's discounted everything I ve 
said," said the teenager. 

"He's just dismissed me as some- 



one with delusions. I'm in shock he 
said none of this ever happened. 

"I wish it were a false memory. C 
doubted myself for a long time, but 
I've lived with it and I know it's 
there and it happened." 

Lawyer Jeff Gindin said what hap- 
pened to his client's daughter is a 
classic case of her therapists plant- 
ing the suggestion in her mind. _ 

"We don't think she's a liar," Gin- 
din said. 

"We feel based on the therapists' 
suggestions she probably does be- 
lieve it happened. For a suicidal, de- 
pressed, very vulnerable person to, 
be told by therapists chat you'll be: 
believed whatever you say is dan-' 
gerous, because it leads to thera- 
pist-induced memories." 

"I've never raped my daughter," 
the man said. "I know chat. My fam- 
ily knows that. Now the judge knows 
that. Ml I'm hoping for is in time my 
daughter will come around. She's 
my daughter and that will never 
change." 



c 



Incest ruled 'false 
memory' 

to, shocked os judge rejects testimony as -product of her mind' 



By Kevin Rollason 

Law Courts Reporter 



A JUDGE dismissed a teenag- 
er's incest testimony yester- 
day as a product of false 
memory syndrome, the first time a 
Manitoba court has recognized the 
syndrome's existence. 

"I think she honestly believes it 
happened to her," Mr. Justice Ken- 
neth Hanssen of Court of Queen s 
Bench said while acquitting the 
teenager's father of incest and sex- 
ual assault charges. 



But he said he had to go beyond l 
simply finding the man not guilty. 

'That person can still suffer a 
stigma in the community. The public 
assumes the person was guilty, but 
got off because of the judge's rea- 
sonable doubt. '■ 

"My view is the alleged assaults 
probably never occurred and were 
really the product of (her) mind." 

A 19-year-old woman had testified 
her father' sexuaJly^assaultedher 

about eight time's while "she was 15. 
She claimed she suppressed the 
memories until she experienced a 
flashback after receiving therapy at 
the Health Sciences "Centre, and 
later St. Boniface General Hospital,- 
for depression. 

But she also testified she had the 
flashback about a week after being 
questioned by a nurse about 
whether she'd been sexually abused 
by her father. ■ _ 

And the teenager - who claims 
her father is the only sex partner 
she's ever had -refused a medical 

examination. , 

With tears rolling down tier 
cheeks outside the courtroom, she 
said although she didn't want her fa- 
ther to go to jail, she couldn't believe 

what the judge said .. oVw 

"He's discounted everything I ve 

said," said the teenager. 
"He's just dismissed me as some- 



one with delusions. I'm in shock he 
said none of this ever happened. 

"I wish it were a false memory. I 
doubted myself for a long time, but 
I've lived with it and I know it s 
there and it happened." 

Lawyer Jeff Gindin said what hap- 
pened to his client's daughter is a 
classic case of her therapists plant- 
ingthesuggestioninhermind. 

"We don't think she's a bar, Gin- 
din said. 

"We~feel based on the therapists' 
suggestions she probably does be- 
lieve it happened. For a suicidal, de-j 
pressed, very vulnerable person to. 
be told by therapists that you 11 be: 
believed whatever you say is dan- 
gerous, because it leads to thera- 
pist-induced memories." ■ pi 

"I've never raped my daughter, 
the man said. "I know that. My fam- 
ily knows that. Now the judge knows 
that. All I'm hoping for is in time my 
daughter will come around. She s 
my daughter and that will never 
change." 



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f.f. 



Fact or 
fictitious 

charges? 

Some violent memories are real; 
some say others can be induced 

i,*. r - -i H ^ n irafn'll art* fhn^ft 



By Kevin Rollason 
Law Courts Reporter 



ONE THING is clear when 
you talk to people about false 
memory syndrome — 
there's iittle middle ground. 
On one side is the belief 
herapists can plant suggestions in 
ie minds of patients who then 
■remember" incidents and falsely 
accuse their parents or others of 
sexually abusing them as children. 

This point of view entered the 
arena of public debate after a 
Pennsylvania couple founded an 
organization to publicize the 
so-called dangers of false memory 
syndrome in 1992. 

The opposing view contends 
memories of childhood abuse are 
true but often suppressed because 
the trauma is too much to handle — 
and the memories only surface 
years later when victims are 
removed from the abusers' 
influence and obtain help. 
Troublesome claims 
Critics denounce false memory 
syndrome as a tool for perpetrators 
to discredit their victims or for 
society at large to dismiss 
troublesome claims of abuse. 
This summer, the American 
Medical Association's council on 
scientific affairs waded into the 
controversy. 

The association said it "considers 
recovered memories of childhood 
sexual abuse to be of uncertain 
Rithenticity, which should be 
subject to external verification. 
The use of recovered memories is 
fraught with problems of potential 
misapplication. 



"Most controversial are those 
memories that surface only in 
therapy and those from either 
infancv or late childhood," an 
association statement continued 

"Few cases in which adults make 
accusations of childhood sexual 
abuse based on recovered 
' memories can be proved or 
disproved." 

PAMELA FREYD founded the 
Philadelphia-based False 
Memory Syndrome 
Foundation with her husband Peter 
after their adult daughter, 
Jennifer, remembered in 1990 that 
her father had fondled and raped 
her as a child. 

They said their family was 
ripped apart by the accusations, 
Jennifer, a psychology professor, 
recalled the abuse under therapy. 
Their story has gained a high 
profile, with the Freyds and their 
daughter locked in a public battle 
that has included spots on network 
talk shows, research papers and 
public speeches. 

Since 1992, the Freyds' 
organization has attracted the 
support of parents with similar 
experiences, including 10 families 
in Manitoba. The group is funded 
through private donations. 

"Child sexualabuse is a very 
serious problem - it deserves 
better than the silliness of false 



^?6 



fd C £ PR & 



->> 



'Hi 



memory cases." Pamela Frcydsaui 
recently in an interview. "We have 
13,000 families who are distraught. 
It isn't the accusation so much as 
the lack of contact with their 
children." 

Frevd said when an accusation of 
abuse' follows the dredging up of 
memories in therapy, claims 
should be examined closely. 

0\V CAN the therapist 
know the truth or falsity 

of the claims without 

external evidence? How do you 
know?" 

Dr. Michael Thomas, a 
psychiatry professor at the 
University of Manitoba, said he 
believes false memories can be 
induced. 

"It would surprise me if anyone 
would say it can't happen," Thomas 
said. "The frequency it happens is 
open to argument. To suggest it 
can't happen is difficult to defend 
because of research data." 

Thomas said research has shown 
memories can be planted under 
hypnosis and people can't 
distinguish between planted and 
actual memories. 

On theother hand, Dr. Peter 
Hays, vice-chairman of the 
University of Alberta's department 
of psychiatry, said he doesn't 
believe traumatic memories can be 
suppressed. 

"With FMS they say they can't 
remember and it's buried, but we 
can ail remember traumatic 
events," said Hays, who was set to 
testify for the defence during an 
abuse trial in June. 

"We remember being tortured if 
it happened to you." 

Hays said he's concerned about 
potential backlash if false 
memories are uncovered only after 
those wrongly accused are publicly 
branded. 

"If you get women falsely 
making sexual assault claims, then 
the ones who are really sexually 
assaulted won't be believed," he 
said. . 

"The real tragedy is for the girl 
who accusesthe parent because 
she has memories induced which 
she will later realize are false. 

"But by the time she does she's 
lost her family." 



Iponei 



■Mi liftHS^ 

■ Sr-t^ r?!fl i'.SS.i ;,*! ; 



Court actions surfacing in 
Manitoba are putting a local spot- 
liqht on an issue making national 
headlines over the last two years 

- whether False Memory 

Syndrome exists. In this special 

report, law courts reporter Kew'- 

Rollason examines the control 

sy surrounding sudden adult 

memories of 

childhood abuse. 



Syndrome before the courts/ At 



Therapy centre sued tor implanting 
false memory; secon d case wei ghed 

Lawsuit /y/ 
challenges 
abuse recall 



By Aldo Santin 
and Kevin Rollason 

Staff Reporters 



ROMA ELIZABETH Hail has 
changed her mind — and tlie 
way she's thinking now may 
well put the legal spotlight on one of 
the most controversial social and 
medical issues of the 1990s — false 
memory syndrome. 

Hart said she became convinced 
during mental health therapy at a St. 
Boniface treatment centre that her 
parents had sexually abused her. 

But now she believes it never hap- 
pened, using an argument identical 
to that of false memory syndrome 
— a condition thai has not been 
medically or legally recogni7.ed in 
Canada. It claims fictitious 
"memories" can be implanted in vul- 
nerable patients through sugges- 
tion. 

Hart is hoping the courts will al- 
low her to sue former Winnipeg psy- 
chiatrist Colin Ross for malpractice, 
claiming he wrongly diagnosed and 
treated her for multiple personality 
disorder for several years, a condi- 
tion ostensiblycaused by childhood 
sexual abuse. 

I«'irsl to file 
Hart's sworn affidavit, which ac- 
companies a court motion expected 
to be scheduled for hearing this 
month, says Ross diagnosed her af- 
ter a single interview. Hail is the 
first of two Manitobans to file an ac- 
tion related to false memory. 

On Friday, George Bergen 
launched a $l-mii!ion action against 
a Christian counselling centre, 
claiming one of its counsellors con- 
vinced his wife she had been ritual ly 
abused by satanic cults and was sub- 
jected to incest and rape. 

Bergen, who is one of the plain- 
tiffs along with his wife and their 
children, claims the therapy ses- 
sions left his wife unable to work, 
take care of their children or per- 
form household chores, 

Meanwhile, according to Hart's 
affidavit: "During weekly psycho- 
therapy sessions with Dr. Ross (be- 
tween October 1986 and August 
1991) he would constantly question 
me about having any memories or 
dreams about incest or sexual abuse 
by my father or any other people 
when I was a child," the affidavit 
reads in pari. 

". , . as a result of (Ross's) influ- 
ence and my failure to maintain my 
convictions in the face of (his) insis- 
tence, 1 began to confess untrue alle- 
gations that my parents had sexu- 
ally abused me as a child." 



Memories 



Court actions surfacing in 

Manitoba are putting a heal 

spotlight on an issue making 

national headlines over the last 

two years - whether False 
Memory Syndrome exists. In this 
special report, law courts reporter 

Kevin Rollason examines the 

controversy surrounding sudden 

adult memories of 

childhood abuse. 




Hart: has filed affidavit 



Inside Story 



■ Facl or fictitious charges? / 82 

If the matter goes to trial, it would 
be the first time Manitoba's courts 
will be asked to rule directly on the 
validity of false memory. 

A two-year deadline for filing suit 
expired last November. But Hart 
will try to persuade a Court of 
Queen's Bench judge to extend her 
rights on the grounds that she was 
incapabie of managing her affairs 
during those two years due to 
"impairment of her physical and 
mental condition caused by the re- 
spondent's negligence." 

Her sworn affidavit claims that, 
as a result of Ross's treatment, she 
suffered such psychological, emo- 
tional and physical damages that she 
can't work full time and will require 
future care. 

Ross would not comment, citing 
confidentiality. He used to practice 
out of a centre at St. Boniface hospi- 
tal and moved to the U.S. in 1991. 



!AJ 



>(/VVv^J 



Sufc ifyt 



"ihauL. (i a>^' j - 



Bergen: blames therapy 

Family 
claims 
it was 
ruined 



ByGlenMacKenzie 

StaffReporter 

A WINNIPEG family is suing a ' 
counselling centre for more 
than $1 million, claiming it 
was torn apart after a counsellor al- 
legedly implanted ideas of ritual 
abuse in a woman's mind. 
■ In a statement of claim filed in 
Court of Queen's Bench against the 
Winnipeg Christian Counselling 
Group, Bonnie Bergen claims her 
counsellor, Tammy Schultz, im- 
planted erroneous memories dur- 
ing a course of therapy in which 
she was "encouraged to recount 
stories of incest, rape and ritual Sa- 
tanic cult abuse," which allegedly 
occurred in Saskatoon and Flin 
Flon more than 20 years ago. 

Bergen, 44, said in an interview 
yesterday that while she was an in- 
cest victim when she was about 20 
years old, she now considers the al- 
leged incidents of ritual abuse "too 
bizarre to believe." 



Nightmares 

Her husband, George Bergen, 60, 
a senior research officer for the 
Manitoba Government Employees' 
Union, who is one of the plaintiffs in 
the suit, said his wife began having 
nightmares in the fall of 1993 fol- 
lowing her therapy sessions, which 
began in March, 1992. 

"She was reliving the Satanic rit- 
ual stories in nightmares. Then she 
had difficulty sorting out what was 
reality "he said. 

Bergen claims his wife's 
"dysfunctional" condition — which 
has yet to be diagnosed as a psychi- - 
atric condition — deteriorated to 
the point where she could no longer 
work, help with the children or 
home and it ultimately broke up 
their marriage. 

Bonnie Bergen said she bears no 
animosity toward the counsellor 
but stands fully behind the lawsuit. 

"I want them to realize they're 
dealing with people who are help- 
less and must be careful." 

Schultz, who holds two masters 
degrees in counselling, refused 
comment on the case,' citing pa- 
tient-client confidentiality. 

But she said she believes false 
memory syndrome can occur — 
even if it's not recognized by the 
medical or psychiatric community 
— and it often comes up in abuse 
cases. 

She added, however, that she was 
surprised to hear of the lawsuit 
against her. 

Officials at Grant Memorial Bap- 
tist Church, with which the coun- 
selling centre is affiliated, couldn't 
be reached for comment. 



(<///i//v - p/~ 6 ftXtfr P/?c 



'I've been through hell' 

Former mayor of Riverton cleared of teen sex assault charges 



By Allison Bray 

Staff Reporter 



A 28-MONTH ordeal is over for 
the former mayor of Rive rton 
whose lawyer says he was 
caught up in "hypersensitivity 11 to 
child sex-abuse allegations. 

Few believed it in the first place: 
not his family, his friends and neigh- 
bors, nor the judge who finally ac- 
quitted Victor Sigurdson of sexually 
assaulting three teenage girls dur- 
ing a school outing. 

And for the first time in more than 
two years, Sigurdson and his family 
can sleep peacefully again. 

"I've been through hell for the ■ 
past 28 months . . .I'm ready to get 
on with life," Sigurdson, 66, said yes- 
terday. 

Ever since he was charged in 1991 
with sexually assaulting three Vir- 
den Junior High students while at 



the helm of a boat at Hecla Island, 
Sigurdson's life has been turned up- 
side down. 

"I received coast-to-coast cover- 
age, complete with details that were 
not even substantiated," he said of 
media reports of his arrest on 
charges of touching in a sexual way 
the 13- and 14-y ear-old girls. 

"It bothers me every time I hear 
of a story like this. I don't like it," 
Sigurdson said. 

"I can now appreciate when I hear 
of a teacher accused of abuse. I 
kno w what they 're going through. " 

Sigurdson's arrest generated 
shock waves through the small In- 
terlake community over which he 
presided as mayor for 14 years until 
his retirement last year. 

Residents who spoke to the Free 
Press following his arrest were in- 
credulous. 



"A lot of them feel for the guy," 
Don Bilinski, owner of the local 
store had said. 

"He's a big part of the community 
and a lot of people feel he's been 
found guilty before being proven in- 
nocent." 

BILINSKI'S WORDS turned 
out to be prophetic. 
Provincial court Judge John 
Enns acquitted Sigurdson on appeal 
of all three counts after a two-day 
trial in Arborg last week, on the 
grounds the allegations could not be 
proven beyond a reasonable doubt. 

But almost a year earlier, Sigurd- 
son's wife collapsed outside the 
courtroom after protesting her hus- 
band's innocence. Provincial court 
judge Ron Morlock had found him 
guilty and sentenced him to a one- 
year conditional discharge and or- 



dered him to attend a counselling 
program forsexoffenders. 

While his lawyer, Jim McLan- 
dress, said the ordeal has taken its 
toll on Sigurdson and his family, he 
said the case illustrates 
"hypersensitivity" to child sex- 
abuse allegations. 

McLandress said what in reality 
was an unintentional brushing 
against the girls' inner thighs as Sig- 
urdson helped them manoeuvre the 
boat while they sat in front of him, 
was misconstrued as being inten- 
tionally sexual. 

Winnipeg psychologist Toby Rut- 
ner said he fears there will be more 
cases like Sigurdson's because chil- 
dren have become oversensitized to 
the point where doctors and teach- 
ers are afraid to touch them out of 
fear of abuse allegations. 



Ex-nun to be tried 

f«\ NORTH BAY, Ont. -A 
JCK former Roman Catholic nun 
[Xhas been ordered to stand trial 

C on a charge of gross 

K ^decency for sex crimes that 
£ allegedly occurred two 
Jj^ decades ago. 

_ The charges of gross 
L- indecency were laid last 
w March against Bernadette 

T^arocheiie,aformerSisterof 
1 fhe Assumption, and Albert 

Lozier of Ottawa, a former 

Brother of theSacred Heart 



Angry dad says agency has no 
right to bar him from girl 









ByRuthTeichroeb 
Social Affairs Reporter 



AN ANGRY father is demand- 
ing a review, of why Winnipeg 
Child and Family Services is 
blocking access to his daughter af- 
ter an extensive probe of sexual 
abuse allegations failed to uncover 
any evidence against him. 

The man says he was falsely ac- 
cused during a bitter custody dis- 
pute with his estranged wife. 
Those who have investigated the 



Inside Story 



g Father flails at shadows / B3 



case haven't been able to determine 
with certainty whether the now-sev- 
en-year-old child was even molest- 
ed, let alone who may have done it 

But they say the case highlights 
the problems they face-and the in- 
creasing expertise required- when 
S out sexual abuse complaints 
arising during custody disputes. 

Sough no statistics are avail- 



able for Manitoba, U.S. studies have 
suggested that between 15 per cent 
and 50 per cent of allegations arising 
in custody/access disputes may be 

In this case, the father has asked 
Ron Fenwick, director of the child 
and family support branch of Fam- 
ily Services, to investigate the agen- 
cy's handling of the matter 

The sexual abuse allegations first 
arose in October 1992. At the time, 
the father had seen his daughter 
only during supervised visits for the 



previous two years because his ex- 
wife had accused him of planning to 
kidnap the child. 

The man lost access to his daugh- 
ter after the mother reported the 
child's allegations to Winnipeg Child 
and Family Services and the police. 

In November 1992, the child was 
exlined at the Child ? otectton 
Centre by Dr. Charles Ferguson 
whose medical findings suggested 
the girl had been sexually abused. 

Tyear later, the child was exam- 
ined again at the centre after alleg- 



ing her paternal grandfather mo- 
isted her This time, two other doc- 
tors found no medical evidence of 

abuse. 

A March 1994 assessment by cen- 
tre social worker Sharon ^ 
Prendereast recommended that the 
father be given supervised access 
Tut the next month, a report sub- 
mitted at the request °f CFS by D. 
Eric Ellis criticized the CPC assess 
ment and said there wasn't enough 

SrrStion to determine what was 
■ best for the child. 



Victor Bargen,. the father's law- 
yer said two motions asking tor ac- 
cess to the child have been turned 
down by a judge over the last year. 
Thereasongive^asthatapsycho- 
Jgist hired by CFS says the child is 
afraid of the father, he said 

But Bargen said he believes the 
child has been manipulated. 

Dave Waters, director of the east- 
ern branch of Winnipeg Child and 
Family Services, said the agency is 
committed to restoring access to me 
father. 



Abuse: 

too many 



s^ft iA& 



cry won 

Province to launch fall probe 
as child-custody cases get ugly 



By Allison Bray 

StaffReparter 



Inside Story 



SO MANY parents falsely ac- 
cuse their former partners of 
child abuse that the govern- 
ment plans a special probe this fall, 
the Free Press has learned. 

At the same time, the provincial 
Children's Advocate is calling for 
changes to. the Divorce Act to give 
children more say in choosing a cus- 
todial parent. Wayne Govereau said 
the system currently sets no legal 
requirement for a judge to consider 
the wishes of the child. 

"It's a nasty, nasty world out there 
for kids," he said. 

The number of abuse allegations 
— both true and false — is making it 
nastier. Although there are no spe- 
cific, statistics, child welfare agen- 
cies have noticed a marked increase 
in abuse accusations during custody' 
disputes over the past few years,- 
said Child and Family Support direc- 
tor Ron Fenwick.' 

"Any conniving individual who 
wants to put the screws to their 
spouse knows any kind of abuse alle- 
gation will get the full force of the 
la w, " said family court lawyer Mary 
McManus. 

Richard Alcock, another family 
court lawyer, quipped that the alle- 
gations have become so common- 
place, divorce papers should be ac- 
companied by a form letter detailing 
alleged abuses. 

"There are enough times it's used 
as a weapon to get back at the part- 
ner," Alcock said. "So when (real 
abuse) is happening, it's taken with a 
grain of salt." 

Dr. Charles Ferguson, director of 
the Child Protection Centre, also 
fears too many parents cry wolf. 



■ Caught in She crossfire / A5 . 

"If (the child) is operating in soci- 
ety in a relatively normal way, then 
the agency will assume the (parent) 
is coaching," he said. 

Keith Cooper, director of Winni- 
peg Child and Family Services, said 
a quarter of the '2,800 child abuse al- 
legations in the province each year 
arise during custody disputes. 

Govereau said his office alone re- 
ceives three or four phone calls a 
week from parents claiming their 
ex-partners are abusing their chil- 
dren. "I could have in excess of 20 
full-time (staff) following up on cus- 
tody/access issues," he said. 

Ferguson said the number of chil- 
. dren in custody disputes who are ac- . 
dually being abused is probably' less 
than .10 per cent of those where 
: abuse'fs claimed. But the psycholog- 
ical damage to children ' used as 
pawns is abuse in itself. 

"Our experience is these children 
are at enormous emotional risk and 
are ill-used. These parents have to 
live with the threat that none of 
them will win the battle," and the 
child could be apprehended on the 
grounds of emotional abuse. 

This fall, a committee of provin- 
cial child welfare agencies will try 
to determine what can be done to 
stem the tide of false allegations. 
Govereau said options could include 
appointing a family advocate to rep- 
resent the child's interests during a 
custody battle. Cooper said a pend- 
ing review of the Child and Family 
Services Act could revamp the law 
to include sanctions against parents 
who maliciously make false claims. 



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Demonic s pectre in Mart e nsville case evaporates 



/--. t- 



Facts fail to support ^ 
satanic ritual cult links 



By Leslie Millin 

Special to the Free Press 

VANCOUVER — Docu- 
ments recently released 
relating to the 
Martensville case of child sex 
abuse seem to indicate this is 
one more addition to thelengthy 
list of improbable charges ot' 
satanic ritual cult activities. 
Such activities are widely 
believed to exist, and people 
both sane and serious will tell 
you so. But do they? Not long 
ago, a detailed computer search 
through the scientific, medical 
and legal literature turned up 
not a single case where there 
was corroboration. 

Many, many accusations exist. 
There is a thriving therapy 
industry based on assisting peo- 
ple who assert that they have 
been victims of satanic cult 
abuse. 

Some of the practitioners 
involved make assertions that 
leave the mind reeling. One 
such, delivered in a respectable 
academic setting, was that the 
sentence "Look after yourself," 
in a postcard from a sister to a 
sister, was an instruction to 
commit suicide to cover up a 
satanic past. 

Indeed, the number of accusa- 
■ tions is in itself odd. An academ- 
ic study, of which unfortunately 
1 have only the briefest summa- 
ry, investigated 12,000 accusa- 
tions without finding a single 
corroborated case. 

That there should be so many 
accusations without a single 
stick of corroboration defies 
probability. 

No doubt satanic cults exist. 
The world is all too full of 
deranged people prepared to 
start up cults, and insecure peo- 
ple who will follow them. 

No one can doubt that evil 
exists. Whoever did what in the 
Bernardo/Homolka case, ghast- 
ly acts were committed. 

And there is no doubt that 
children are sexually abused, 
and that their abusers seek to 
conceal this fact, and that some- 
times their abusers conspire 
with each other in both abuse 
and concealment: Mount Cashel 
taught us this. 

Nevertheless, the fact is that 



£££- 




Sterling was only one convicted in Martensville case. 



most cults become known, 
because they require their 
adherents to behave in unusual 
ways that attract attention: 
breaking off contact with fami- 
ly and friends, attempting to 
proselytize, or prancing down 
the public streets wearing 
strange garb and beating a 
drum. 

FURTHER, THE successful 
concealment of systematic 
child abuse tends to hap- 
pen in a closed world, such as an 
orphanage or residential school 
or centre for the handicapped. 
No such closed world existed in 
Martensville. Nor are satanic 
abuse accusations typically 
associated with such closed 
worlds. 

And it is interesting that 
where sexual abuse of children 
has been successfully prosecut- 
ed almost entirely on the evi- 
dence of the accusers, this has 
not been on the basis of "recov- 
ered memory," or intensive and 
suggestive interrogation of chil- 
dren. 

Rather, it has been on the 
basis of acute and all too painful 
memory, on consistency of 
method — child abusers are 
almost always repeat offenders 



— and often on confession by 
the accused in the face of over- 
whelming, credible testimony. . 

Without for one second dis- 
puting that such offenders com- 
mitted evil acts, clearly they did 
not, for the most part, do so 
because they espoused evil as 
an end in itself. Rather, they 
wanted self-gratification, and 
were generally indifferent as to 
the misery they inflicted on 
children incapable of self- 
defence. 

But for those who engage in 
satanic cults, the whole point of 
the matter is to further evil as 
an end in itself. 

Where cult activities involve 
secret meeting places, the use 
of symbolic objects and para- 
phernalia, and the repeated 
abuse to the point of murder of 
children, the chances of some 
sort of slip-up revealing some 
sort of corroborating evidence 
have to be significant. 

In the documents released on 
the Martensville case, there 
were originally some ISO 
charges of sexual child abuse, 
many of them linked to satanic 
ritual. The eventual outcome 
was a single conviction of one 
man, Travis Sterling, for 
improperly touching a nine- 



year-old girl while she was at a 
day-care centre run by his par- 
ents. 

But the Martensville police 
chief believed in the satanic 
cult aspect of the case. He 
believed that children were 
taken from the day-care centre 
to "the Devil Church," where 
they saw other children killed 
and dismembered, 

"1 believe these events did 
take place," he said in a confi- 
dential report cited by the 
RCMP task force set up to try to 
make some sense of the affair. 
He also made use of an organi- 
zation called Cult Out Min- 
istries, whose name speaks for 
itself, 

"This error led to the 
Martensville police department 
^suspecting a large number of 
"innocent persons as suspects 
involved in the cult," the RCMP 
report says. 

"On numerous occasions this 
(Martensville) police depart- 
ment alleged complex conspira- 
cies to the more bizarre 
allegations of pending human 
sacrifices. To date, task force 
investigators have found no evi- 
dence to substantiate . . . (this) 
allegation." 

Some months ago, I attended 
a forum where those who 
believe in recovered mem- 
ory of childhood abuse debated 
those who strongly doubt the 
validity of the techniques used 
in much of recovering such 
memories, while not denying, of 
course, that such abuse hap- 
pens. 

The forum heard a long inter- 
vention from the floor by a 
woman who described in detail 
the ritual satanic murder of a 
child who was her best friend. 
The detail was formidably con- 
sistent, as such recovered mem- 
ories often are. 

No one could doubt her sin- 
cerity. No one could doubt her 
anguish. 

But no one there, expert or 
otherwise, on either side of the 
controversy, advised her to go 
at once to the police and accuse 
those who had committed such 
terrible crimes. 

And that speaks for itself. 

(Leslie Millin is an editor with 
the ttsuus Network.) 




A^rsL 



/) /V^^Xk. y/jp £ 




By Ian Bailey 

Canadian Press 



ST. JOHN'S, Nfld. - The 
Supreme Court of Canada has 
cleared a former Christian 
Brother at the Mount Cashel 
orphanage of indecent assault in a 
blunt ruling that questions evi- 
dence from three victims. 

Joseph Burke now stands con- 
victed only on one count of assault 
causing bodily harm for beating one 
of the boys. Three indecent assault 
convictions were thrown out. 

"He seems happy with the 
result," lawyer Marvin Storrow 
said yesterday from Vancouver 
after speaking with Burke, now liv- 
ing in the West Coast city. 

But the lawyer said Burke is "not 
happy with the fact that he had to 
suffer through six or seven years 



of fighting this matter." 

The St. John's orphanage, now 
demolished, became known across 
Canada for beatings and sexual 
abuse that occurred in the 1970s at 
the hands of the brothers, mem- 
bers of a Roman Catholic lav order 
who ran the institution. 

Mount Cashel's horrors rocked 
Newfoundland, which has a signif- 
icant Catholic community. The 
tales of abuse bubbled for 15 years 
before authorities acted. 
Never jailed 
Burke was arrested in April 1989 
on charges involving alleged inci- 
dents between 1974 and 1931 He 
was convicted in 1991. He was sen- 
tenced to 25 months but was never 
imprisoned because of appeals. 

In a blistering ruling released 
yesterday, Justice John Sopinka 
wrote one boy who testified against 



Burke "has a vivid imagination" and 
questioned "whether or not there 
was any core of truth" to his claims. 
He cited the "chronic dishon- 
esty" of a second witness as he 
questioned whether that boy's evi- 
dence was credible. 

"If there were ever a witness 
upon whose evidence it is unsafe 
to rely as the basis for a conviction, 
(this boy) must be that witness." ' 
To conclude, Sopinka wrote: "I 
simply cannot accept that any trier 
of fact, acting judicially, could have 
found any merit in the claims of 
either (witness)." 

Sopinka said the testimony of a ' 
third witness caused "great con- ' 
cern." 

None of the boys can be named. 
The presiding judge at Burke's 
trial imposed a ban on identifying 
them. 



Parents group vindicated 
after MD's rebuke 






_ £4 

By Bill Redekof! 
staff Re porter ... 

THE PARENTS Helping Par- 
ents group said yesterday u 
feels vindicated after the 
head of the Child Protection Cen- 
uewSs disciplined by the licen*- 

\n° body for Manitoba doctors 

The group had helped a Wm- 
nipegflther^ressforanmquuv 

into a CPC assessment that nib 
four-year-old daughter showed evi- 
dence of sexual abuse. 
%ow that this case recogniz > 
the flawed process of sexual abuse 



investigations at the CPC I believe 
this will be a gateway for ^other 
nirents to bring then- cases foi - • 
P warf« showing sig^cantpn*- 
lems," group president Louise 
Malenfant said yestei day. 

She was referring to a letter 
from the college to Dr. Charles Fei e 
"uson the head of the centre. The 
FeterYaid his 1992 examination of 
the child had been "below an 

acceptable standard. 
Eadier, the college's complaints 

committee had rejected the com- 
plaint against Ferguson. ' 

Dr William Pope, the colleges 
assistant registrar, said the com- 
mittee's original assessment of the 
case was based on information 
available to it at the time. 

Other material has since been 

brought forward, leading the col- 

. le^e's investigation chairman, Dr. 

Claude Murphy, to reverse that 

assessment, Pope said. 

He refused to discuss the con- 
tents of the material, citing confi- 
dentiality under the Medical Act. 

"The committee does what it can 
do under the circumstances, said 



Pope, adding he sees no reason to 
change the process. 

The father, who swears he was. 
falselv accused, said he will also 
use the college's letter to sue Fer- 
guson for negligence, a suit that 
could be launched as early a* 

The father's lawyer, Victor Bar- 
gen, said they plan to sue Fergu- 
lon for damages, including 
monetary compensation. 

"There's incredible damage done 
to a child by a misdiagnosis like 
I this," Sargen said. . , 

The girl has been receiving sex- 
ual abuse therapy from child and 
family services, he said. _ 
■ "It's been an absolute night- 
mare," said the father, who- can't 
be identified in order to protect the 
child's identity."There is not an 
aspect of my life that.hasn t been 
absolutely shattered. . 

"I don't know who my friends 

are. I don't know who believes me 

and who doesn't believe me." _ 

He hopes the college's criticism 

: of Ferguson's assessment will help 

him obtain visitation rights. He 

hasn't seen his' four-year-old daugn- 

■ ter in three years. 



r 



^fj^ 



Friday, Septem&er:f5»v1$95£ 



Child-abusee 




reprimanded over exam 



By Bill Redekop 
and Bud Robertson 

Staff Re porters „___ 

THE LICENSING agency for 
Manitoba doctors has written 
a stem letter to the province's 
foremost child-abuse expert saying 
he mishandled an examination that 
has kept a Winnipeg man from see- 
ing his daughter for three years. 

Dr. Charles Ferguson's methods 
for examining the four-year-oid girl 
"were below an acceptable stan- 



Inside Story 



Parents group vindicated /B3 



dard," says a letter by Dr. Claude 
Murphy, the investigative chairman 
for the College of Physicians and 
Surgeons of Manitoba. 

The reprimand was revealed 
Wednesday in a letter to the father. 
The man, who cannot be named in 
order to protect the child's identity, 
had appealed a decision of the col- 
lege's complaints committee. 

The committee originally sided 



with Ferguson, who is director of the 
Child Protection Centre. 
' Child and Family Services refers 
most children alleged to have been 
sexually abused to the CPC for medi- 
cal examinations. 

In the letter, Murphy said Fergu- 
son should "review his criteria for 
performing an examination on a 
child in this situation." 

Murphy added that the letter of 
criticism will be kept on file. 

Ferguson said he stands behind 
his examination of the girl and is 
seeking legal counsel concerning 



ramifications of the letter. 

"I'm not really devastated, ne 
said. "I'm' not going to slit my 

wrists." „ ■ u-~f 

Child and Family Services chief 
executive officer Keith Cooper said 
the case will be reviewed in light ot 
the college's new findings. 

But he said CFS has no intention of 
severing its ties with the centre. 

The girl's mother made allega- 
tions of physical and sexual abuse 
against the father during a bitter 
custody fight in 1992. Police investi- 
gated but charges were never laid. 



In a report to Child and Family 
Services, Ferguson reported the 
girl's hymen was broken "compati- 
ble with digital penetration." 

The little girl said the father 
poked her with pins and stuck a 
knife in her buttocks. 

' But two other physicians who ex- 
amined the girl 13 months later at 
the Child Protection Centre dis- 
agreed. They said the hymen had 
not been broken, nor had abuse 
taken place. The second examina- 
tion was conducted after persistent 



complaints by the father. 

The father also volunteered for 
two psychiatric assessments to de- 
termine whether he has pedophuic 
or aberrant tendencies. 

! "There is nothing in the history or 
the examination to indicate the pres- 
ence of a sexual or paraphilic disor- 
der " wrote Dr. Stanley Yaren, the 
province's chief forensic psychia- 
trist, after interviewing the father. 

"He seemed to understand the ap- 
propriate boundaries," said psychia- 
trist Dr. Gail Robertson. 



Custody disputes fertile ground 
for false abuse charges: experts 



ByRuthTeichroeb 

Social Affairs Reporter 



CUSTODY AND access dis- 
putes between warring par- 
ents provide fertile ground for 
false sexual abuse allegations, ex- 
perts say. 

Margo Buck, associate director of 
Winnipeg's Child Protection Centre, 
says American studies estimate up 
to SO per cent of child sexual abuse 
allegations arising from such dis- 
putes may be false. 

"It's a very controversial issue," 
Buck says. "I have a feeling that's 
probably true. But it's very difficult 
to gauge." 

Those statistics are substantially 
higher than the estimated five to six 
per cent false-allegation rate in gen- 
eral child sexual abuse cases. 

Such disturbing figures point to 
the difficulties of investigating the 
increasing number of sexual abuse 
complaints that have cropped up 
during custody disputes over the 
last five years, Buck and others say. 
"I've never seen such messes," she 
says. "Often they are just riddles." 

While ' professionals emphasize 

that most abused children do tell the 

i truth, everyone agrees that sorting 

••out custody-related allegations re- 

qu lires special expertise. 

btjit the issue of how to identify 



false allegations has fuelled heated 
battles between professionals. 

"Some dismiss custody and sepa- 
ration allegations too quickly, while 
others won't acknowledge the 
higher rate of false allegations ex- 
ists," Buck says. 

In the early 1980s, when society 
was just beginning to acknowledge 
the prevalence of child sexual 
abuse, most professionals believed 
that children weren't capable of ly- 
ing about such matters. 

But in recent years, both the 
courts and child protection officials 
have realized that assumption is too 
simplistic. 

For example, medical assess- 
ments of such cases have improved 
over the last decade, Buck says. 
When doctors first began examining 
children for sexual abuse, norms 
about what a healthy vagina looked 
like in a young girl didn't exist. 

In the past, non-specific medical 
findings — like redness in the geni- 
tals — were often automatically 
used to reinforce a disclosure, she 
says.' 

Now, medical findings are used 
more cautiously, in the context of all 
other information, she says. Medical 
diagnoses of sexual abuse — except 
in cases of extreme trauma — are 
rarely conclusive by themselves. 

False allegations are not necessar- 



ily prompted by a malicious parent 
but may simply arise because of 
anxiety, she says. 

An overly anxious mother, caught 
up in a bitter custody dispute, may 
overreact when a child complains 
dad "hurt her bum," Buck says. 

The mother may immediately in- J 
terpret that as a sexual reference 
when the child might be complain- 
ing about rough handling during a 
diaper change, she says. 

If the child is also having night- 
mares — which can be a sign of ei- 
ther sexual abuse or divorce-related 
emotional turmoil — the scene may 
be set for false allegations, she says. 

Dr. Eric Ellis, a Winnipeg psychol- 
ogist, says assessing sexual abuse 
allegations arising from custody 
conflicts is the " hardest work I do. " 

In sexual abuse investigations, the 
word of a child — who is disadvan- 
taged by virtue of language skills 
alone — is pitted against that of an 
adult, he says. 

In addition, mental health profes- 
sionals have no scientifically valid 
methods of determining when some- 
one is being truthful, he says. 

While children rarely lie about 
sexual abuse, custody disputes are 
the most common backdrop for 
false allegations, he say s. 

"Warring parents have come to 



realize that this can be . , .a way to 
stop access between parent and 
child." -. 

Too often, poorly trained profes- 
sionals botch abuse investigations 
as well, he says. 

But in the end, the bulk of such 
cases have insufficient evidence to 
go to court, he says. Instead, es- 
tranged parents and children need 
help repairing badly damaged rela- 
tionships, 

"In the long run, all children need 
some relationship with the departed 
parent," 



W 1 

T ¥ v 



■INNIPEG POLICE Sgt. 
Robin Parker says they al- 
ways begin with the as- 
sumption that an abused child is tell- 
ing the truth. 

But if they're suspicious about an 
allegation, they may ask a polygraph 
specialist to do a "statement 
validity" assessment, he says. 

That involves assessing factors 
like whether the language used by 
the child is age-appropriate or 
whether the child sounds coached. 
They also look for corroboration of 
the child's statement, he says. 

Police have not yet charged a par- 
ent for coaching a child to give false 
statements, but Parker says he ex- 
pects that could happen if the evi- 
dence were available. 



Accused father 



/3P 



flailing at shadows 

Sex abuse allegations keep daughter away for two years 



ByRuthTeichroeb 

Socia l Affairs Reporter 

FROM THE father's perspective, it's been a 
no-win situation of nightmarish propor- 
tions. , 

■ He was in the midst of a bitter custody dispute 
with his estranged wife when the sexual abuse al- 
legations cropped up from his young daughter. 

From the beginning, he has maintained his in- 
nocsncG. 

And after two years of investigation by police, 
doctors, psychologists and social workers, no one 
is sure whether the child was molested, let alone 
who may have done it. 

Nevertheless, the father hasn't been allowed to 
see his seven-year-old daughter for two years. 

He's furious, and has complained to every pos- 
sible authority about what he believes is an injus- 
tice. 

He believes his ordeal represents a failure ot 

■ the system which investigates sexual abuse com- 

■ plaints. „. . j- 

. To back his claim, he points to conflicting medi- 
cal evidence and opposing recommendations 

■ from psychologists and social workers. 

On the other hand, professionals involved in the 
, case say sexual abuse allegations that arise dur- 
; ing heated custody disputes are always complex. 
Side of caution 

■ Any complaint of sexual abuse from a child 

■ must be taken seriously and that often means err- 
' ing on the side of caution, they say, 

The father's problems began in October 1992, 
when his estranged spouse reported that their 
then-five-year-otd daughter complained he 
touched her private parts. 

The abuse had allegedly taken place during su- 
: pervised vists at the father's home. He'd agreed 
to supervised visits — overseen by paid profes- 
sionals — two years before when his estranged 
: spouse accused him of planning to kidnap their 

■ The mother took the child to Winnipeg Child 
; and Family Services where the girl repeated her 
: allegation, adding her father had also pinched her 
; privates with pliers. 

Those allegations set the wheels of the system 
in motion and resulted in the father losing access 
to his daughter. 

Winnipeg police interviewed the child on video- 




WAVNE GLOWACKI I WINNIPEG FHEE PRESS 



Dad-daughter relationship shattered, 

■ CFS holds all cards /A1 



tape and talked to her parents. 

The father was asked to take a lie-detector test, 
which he refused on the advice of his lawyer. He 
later passed a privately administered lie-detector 

test. 

When Dr. Charlie Ferguson, director of Winni- 
peg's Child Protection Centre, examined the child 
in November 1992, he found medical evidence to 
suggest the girl had been sexually abused. 

Around the same time, CFS hired play therapist 
Dr. Susan Hartley to work with the child. 

In November 1993, the child told Hartley that 
her paternal grandfather had molested her while 
her father watched. CFS reported those allega- 
tions to police in April 1994. 



The next month, the girl was re-examined at 
CPC, this time by Dr, Debby Lindsay and Dr. Sue 
Wood. They concluded there was no physical evi- 
dence of sexual abuse. 

The father seized upon the differing medical 
reports as proof he was innocent and eventually 
complained to the College of Physicians and Sur- 
geons of Manitoba about Ferguson. 

But the College has backed Ferguson, saying 
sexual abuse exams are a "somewhat inexact 
science" and that he was legally and morally 
bound to report what he saw. 

CPC social worker Sharon Wazney-Prender- 
gast also did a parent-child assessment in March 
1994 and recommended that supervised access 
be given to the father. 

She noted that the father had very limited op- 
portunity to abuse the child in the violent manner 
described and that the allegations could be re- 
lated to the contentious custody dispute. 

She also recommended the mother get counsel- 
ling to help her cope with the father's access to 
the child and suggested the father undergo a psy- 
chological assessment. 

Instead, the next month a CFS worker asked 
Dr. Eric Ellis to critique the CPC's parent-child 
assessment. Ellis concluded the assessment was 
poorly done and that there was insufficient infor- 
mation available to decide whether the child's al- 
legations were valid. 

MEANWHILE, A judge twice denied the fa- 
ther access to his daughter last year, cit- 
ing concerns raised by CFS and the thera- 
pist that the child was too fearful of him. 

No criminal charges were laid against the fa- 
ther or grandfather because of insufficient evi- 
dence. The custody dispute hasn't gone to trial be- 
cause of a series of delays instigated by both par- 
ties. 

Dave Waters, director for the eastern branch of 
WCFS, said they are willing to work towards ac- 
cess for the father. 

But he also said that the child must be given 
time to get over her fear of her father. 

But the father says he's caught in a catch-22. 
He believes the child has been manipulated and 
that the more time that goes by, the harder it will 
be to repair their relationship. 

After a two-year battle, the father said his only 
hope is to push for a trial and wish for the best. 



j3f^ 



in/D<?^ 



So^ 



Sextria 
halts after 
third juror 
dismissed 

'A Court of Queen's 
Bench judge declared a 
mistrial in the case involv- 
ing a man accused of sex- 
ually assaulting a young 
girl after a third juror was 
dismissed. 

Justice Rodney Mykle 
dismissed the juror from 
duty Wednesday morning 
just prior to what was sup- 
posed to be the start of 
closing arguments from 
the Crown attorney and de- 
fence lawyer. 

Two other jurors were 
dismissed Tuesday prior to 
testimony. 

Mykle told the remain- 
ing nine jurors before 
declaring a mistrial that 
the Criminal Code allows 
for a trial to continue with 
10 jurors but no less. 

"The events that un- 
folded could not have been 
foreseen before the trial 
began," Mykle said. 

The case will go to as- 
signment court in March to 
set a new trial date. 

The 34-year-old Bran- 
don man has pleaded not 
guilty to sexual assault and 
sexual interference. The 
incident is alleged to have 
occurred between April 
1991 and November 1993. 

The girl, now 10, testi- 
fied on Monday that the in- 
cident occurred on a sum- 
mer day, but she couldn't 
remember how old she was 
or what grade she was in 
when it happened. 

The girl said the man, 
a family friend, fondled 
her genital area and kissed 
her in his apartment. His 
apartment was two doors 
down from the girl's apart- 
ment. 

The man, who cannot 
be named to protect the 
identity of the girl, re- 
peatedly said during his 
testimony he did not sex- 
ually assault the girl. 



Chisel's chames 



BfiMMiJ ^# 



baffle friend 



7 i/ 



^(\(\ 

•& 



vx 



By Scott Gibbons 
The Brandon Sun 



A Brandon man repeated- 
ly told a Court of Queen's 
Bench jury Tuesday that he 
never sexually assaulted a 
young girl. 

The man, who can't be 
named by court order to 
protect the identity of the 
girl, said during cross-exam- 
ination by Crown attorney 
Garry Rainnie that he has no 
idea why the girl would 
make the allegation. 

"I find this truly embar- 
rassing," the man said. 

The 3'1-year-old man has 
pleaded not guilty to sexual 
assault and sexual inter- 
ference. The incident is al- 
leged to have occurred some 
time between April 1991 and 
November 1993. 

The girl, now 10, testified 
Monday that the man, a 
close friend of the family, 
sexually assaulted her one 
summer day but she couldn't 
remember how old she was 
or what grade she was in 
when it happened. 

The girl said she was 
playing in a paddling pool in 
the backyard of the apart- 
ment block while her mother 
and the man sun tanned that 
day. And when the man went 
to his apartment, which was 
two doors down, the giri fol- 
lowed him. 

Once in the apartment, 
the girl played with a teddy 
bear that belonged to the 




man's son before he took her 
into his bedroom and fondled 
her genital area, she said. 
The man then kissed her 
before they left the apart- 
ment. 

The man said it was poss- 
ible there was a summer day 
when the girl followed him 
into his apartment, which he 
shared with his common-law 
wife, and played with the 
teddy bear. 

He also said it was poss- 
ible he may have played with 
the girl by bouncing her on 
his knee in his bedroom, but 
at no time did he sexually 
assault her. 

Meanwhile, the man tes- 
tified that in addition to 
babysitting the girl and pick- 
ing her up at day care for her 
mother, the girl would come 
almost daily to his family's 
apartment. 

The man said he felt he 
was filling a void in the girl's 
life because her natural 
father was never around. He 
added she needed attention. 

Other defence witnesses 
testified Tuesday that the 
girl sought attention. 

A day-care owner, who 
looked after both the girl and 
the man's young son and who 
lived in the same apartment 
block as the two, said the giri 



craved attention and affec- 
tion. 

The woman also said the 
man and girl got along very 
well. 

Another mother who 
lived In the block said she 
caught the girl falsely accus- 
ing her daughter in order to 
get her into trouble. The 
woman also said she be- 
lieved the girl wanted atten- 
tion. 

A third mother testified 
that the impression in the 
neighborhood was the girl 
was dishonest. However, she 
said she couldn't speak from 
any personal experience. 

The girl's mother said 
during cross-examination by 
defence lawyer John McAm- 
mond that her child had be- 
havioral problems, was hard 
to control and had run away 
several times. She also said 
the girl likes attention and, 
like all children, was known ' 
to tell the odd lie. 

The mother said she tried 
to get counselling for the girl 
from the Brandon Mental 
Health Centre to help control '. 
her. Workers there sug- 
gested the girl might be a 
sexual abuse victim, the 
mother said, and that they 
wouldn't be able to counsel 
her until she was assessed 
for abuse. 

The trial before Justice 
Rodney Mykle and the five- 
man and five-woman jury 
continues today. Two jurors 
were dismissed at the start . 
of Tuesday's testimony. 



^Wi nnipeg Sun Wedne sday July 15 1993 local 3 



Woman says doc \ 
multi-personality abuse idea 



KATHLEEN MARTENS 

Staff Reporter 



.After complaining of stress, a 
Winnipeg woman says she was 
encouraged to believe she had 
multiple personalities as a result 
of childhood sexual abuse. 

Roma Hart, 39, claims a com- 
bination of drugs and therapy 
led her to develop the feeling 
she had been abused as a child 
and her parents were to blame. 

She almost went to police to 
lay charges, but started to doubt 
her retrieved memories. 

"I heard about the false-memo- 
ry syndrome and just sort of decid- 
ed on my own that this is probably 
what happened to me," Hart, a 
member of the local chapter of the 
False Memory Syndrome 
Foundation, said yesterday. 

The Manitoba chapter has a 
support group in Winnipeg. 
Hart has detailed her allega- 



tions against Dr. Colin Ross, a 
psychiatrist who formerly prac- 
tised in Winnipeg, in a civil suit 
and on the Sally Jesse Raphael 
talk show. -. . '• 

She says a former patient in 
Texas is also suing Ross. ■■-. 

There is controversy about so- 
called memory enhancement 
techniques in which - psy- 
chotherapists use drugs or hyp- 
nosis to help patients "recover 
childhood memories. 

False accusations 
The Canadian Psychiatric 
Association released a state- 
ment in 1996 saying memories ot 
childhood sexual abuse, recov- 
ered during adulthood are not 
reliable and should not be 
accepted without corroborating 

evidence. ■ ■ 

There is a risk that such tech- 
niques can lead to false accusa- 
tions, the association said m. a 



position paper to its members. 

Hart says Ross seemed to be 
preoccupied with sexual abuse 
being the cause of her ills.. And 
she couldn't shake the possibili- : 
ty altogether. 

■■ "It only took a few more ses- 
sions to convince me that, yeah, 
maybe (my parents) did sexually 
abuse me." 

St Norbert resident George 
Bergen got involved with the 
False Memory Syndrome 
Foundation, which is headquar- 
tered in Philadelphia, after his 
wife had a bad experience with 
a therapist. He now uses his pro- 
fessional research experience 
outside work to help affected 
families;" V .■ - 

"I don't doubt that it (child 
sexual abuse) can bause-serious 
problems (in adulthood); But 
false memories of abuse can be 
implanted by therapists, Bergen 
.sai.dr , . ;VfVvv .-.'» .-.'... 



Nightmare Psychiatry: Delusions of Satan, 
ET abduction, and the cultivation of false 

memories 



By Douglas Mesner (www.process.org) 



Read the works of Dr. Colin Ross, they were all telling me, He has proven everything! 
CIA sex-slave producing mind-control programs, international conspiracies to cover-up 
crimes of Satanic cult activities, all proven beyond any reasonable doubt in the writings 
of this esteemed psychiatrist specializing in dissociation and trauma. 

These served as ill endorsements for the credibility of Dr. Ross coming, as they did, 
from members, followers, or defenders, of a cult-like conspiracy theory-based collective 
known as S.M.A.R.T. (Stop Mind-control And Ritual abuse Today). Previous to these 
urgent entreaties that I educate myself of the Doctor's works, I had attended - and 
subsequently wrote a report about - S.M.A.R.T.'s annual conference in August of 2009 
where I sat dumb-struck for an entire weekend, listening, as speaker followed speaker to 
barrage their overly-credulous audience with impossibly absurd scenarios of occult 
crime, remote mind-control, and even inter-dimensional demon conjuring . It was the 
expressions of doubt within my conference report that prompted the emails and internet 
message board comments suggesting that Ross might help to dispel my ignorance. 

According to their website, "The purpose of S.M.A.R.T. is to help stop ritual abuse and 
to help those who have been ritually abused. We work toward this goal by disseminating 
information on the connections between secretive organizations, ritual abuse, and mind 
control, by encouraging healing from the damage done by ritual abuse and mind control, 
and by encouraging survivors to network." As I learned at the conference, they even 
offer the tools to combat the sinister mind-control of these "secretive organizations": A 
vendor in the lecture room was selling a slightly more elaborate version of the tin-foil hat 
in the form of steel mesh-lined baseball caps meant to block electromagnetic cranium- 
invading frequencies. It was the very stuff of paranoid delusion, the purveyors of which 
felt certain that Dr. Colin Ross had legitimatized it all. 

So, who is Dr. Colin Ross? According to his website: "Dr. Ross is an internationally 
renowned clinician, researcher, author and lecturer in the field of dissociation and 
trauma-related disorders. He is the founder and President of the Colin A. Ross Institute 
for Psychological Trauma." And, "In addition, Dr. Ross has authored over 130 
professional papers, has reviewed for numerous professional journals and grant agencies 
and is a past President of the International Society for the Study of Trauma and 

1. From a lecture given by woman called "Royal" who appeared to be about 40 years old, 
yet claimed to be a victim of Nazi Doctor Joseph Mengele: "My experience with Mengele 
involved much of the trauma-based mind control involving core programming (such as 
End-Time programming) that is connected to the global take over. He used the Psychic/ 
Spiritual dimensions using, what I have come to call "demonic harmonics", which 
involves using musical tones and quantum physics to open up portals into the spiritual 
realms." http://www.freedomrunministries.org/articles/PostAbortiveStressRA.pdf 

2. Following the publication of my report upon the S.M.A.R.T. conference on Examiner.com, the organiser of 
the conference - self-described masonic mind-control victim, Neil Brick - went all to pieces, calling the editor's 
offices and posting hysterical online comments regarding my piece wherever he could. His fellow paranoiacs 
followed suit, and it was in the resulting online exchanges I engaged in with some of them that I was helpfully 
directed to the works of Dr. Ross. (Eventually, the S.M.A.R.T. crowd managed to cow a harried editor into 
pulling my piece entirely. The editor called me to suggest I might consider measures of increased personal 
safety, so disturbed and frenzied was the anger that these people seemed to be focusing on me. The poor 
fellow clearly hadn't the constitution for the harassment suddenly belaboured upon him.) 



Dissociation." Dr. Ross has even acted as a consultant for the Showtime television 
series The United States of Tara about a troubled housewife who suffers from a case of 
the mythic Multiple Personality Personality Disorder (MPD), now known as Dissociative 
Identity Disorder (DID). 

This all makes for an impressive sounding resume, but a Google search of "Dr. Colin 
Ross" readily reveals some rather questionable material as well - the most prevalent of 
which regards Ross's application to the James Randi Educational Foundation's 
Paranormal Challenge, which offers one million dollars "to anyone who can show, under 
proper observing conditions, evidence of any paranormal, supernatural, or occult power 
or event." Ross's paranormal claim? He claims the power to shoot electromagnetic 
radiation from his eyes. 

As far as Ross "proving" the existence of a satanic conspiracy and CIA mind-control, 
of course he's done nothing of the sort. What Ross has done is collected and published a 
number of documents - available to anybody by way of Freedom Of Information Act 
request - relating to the CIA's MK-ULTRA mind-control experiments that began in the 
1950s, continuing till at least the late '60s, in response to Cold War fears that the 
Soviets had perfected the same. 

In the course of the project's mind-control research, MK-ULTRA experimented with a 
variety of drugs - sometimes on unwitting citizens - in an effort to find the perfect truth- 
serum. While some drugs made most subjects more chatty, none reliably provoked the 
unrestrained revelation of guarded secrets that experimenters had hoped for. In fact, 
the potential for the subject to divulge unreliable, false, fabricated information was found 
to be so high that the drugs employed as truth serums were eventually disregarded as 
useless. 

Similarly, hypnosis was concluded to be worthless insofar as military applications are 
concerned. Ross nonetheless suggests - flaunting the existence of documents that 
demonstrate experiments in hypnotic mind-control were attempted - that the United 
States is currently engaged in the production of hypnotically brain-washed agents, 
"Manchurian Candidates", to carry out Top-Secret operations and assassinations. 

The irony of Ross's self-styled expertise regarding MK-ULTRA is that knowledge of the 
actual results of the MK-ULTRA experiments should have served to correct him - in 
advance - of errors made in his clinical practice: As a therapist working with Multiple 
Personalities, Ross has used many of the same techniques proven unreliable during MK- 
ULTRA to extract information from his client's "alters" (alternate personalities), including 
hypnosis and "truth serum" (sodium amytal). 

The fact that Ross specializes in DID, and the fact that he is a conspiracy theorist are 
not at all independent of one another. The theory of DID - unsupported by science (but 
well-worn as a fictional plot device) - is that certain traumas, particularly that of 
childhood sexual abuse, can prove so incomprehensible and damaging to the victim's 
psyche that, as a protective measure, the memory of this trauma is re- 
compartmentalized in some dark corner of the mind where it is then consciously 
inaccessible to the victim. The victim who represses memories thus then develops 
"distinct identities or personality types" of which they also aren't consciously aware, but 
which "recurrently take control of the person's behavior". It is these alternate identities 
that retain the traumatic memories for the victim. Treatment for this condition often 
relies on the recovery of these repressed traumatic memories. The victim, it is 

3. Confusingly, Ross wrote a paper for a journal, The Anthropology of Consciousness, 
that explains that his is not a personal power. Everybody - according to Ross - emits 
higher EEG from the eyes. This, he continues, may explain the myth of the Evil Eye, as 
well as the feeling of being stared at. Aside from the fact that ocular artifact (EEG peaks 
in response to minor eye movements) is a well-known phenomena to neurologists, the 
idea that other individuals may somehow sense the EEG of somebody staring at them is 
based on no credible evidence (see Skeptical Inquirer debunking of 

Sheldrake: http://www.csicop.org/si/show/ 
can we tell when someone is staring at us ) 

4. An excellent history of MK-ULTRA mind-control/truth serum experiments is given in 
Dominic Streatfield's Brainwash, 2007, St. Martin's Press 



presumed, must confront these hidden traumas so as to assimilate them into the 
conscious mind, thereby making the mind "whole" again. 

Some therapists - in what is known as "guided imagery" sessions - actually 
encouraged their clients to visualize and describe what it would be like if their father, 
brother, or whatever chosen perpetrator had raped her. After constructing some 
reasonably plausible, if horribly disturbing scenario, she would then be told that this 
telling of events only occurred to her in this way because her unconscious mind was 
relaying her actual information regarding true events. 

It is a belief in the historical accuracy of repressed memories, and the continued 
encouragement of this belief within a certain fringe sub-set of the psychotherapeutic 
community, that allows S.M.A.R.T. to maintain their delusions. The "facts" of Satanic 
Ritual Abuse and Mind-Control were almost entirely revealed to them in recovered 
memories of abuse they believe themselves to have suffered. The reality is, "memories" 
that are recovered through hypnosis, sodium amytal interviews, and guided imagery 
sessions - indeed, recovered memories of any kind - have been shown to be nearly 
entirely worthless insofar as historical accuracy is concerned. The potential for outside 
contamination and confabulation is too great, and in the case of recovered memories of 
Childhood Sexual Abuse, many have come to recognize that their recovered memories 
were indeed False Memories: memories of events that never happened, but which they 
believed must have been true (most often under the influence of a therapist) because it 
served an explanatory function in their lives at the time. 

Hypnotic regressions meant to bring forth memories of past traumas are more likely 
to bring forth bizarre fabrications of events that have never occurred. Worse, when the 
subject is aware that the point of the regression is to uncover sexual abuse, the 
fabrications will likely include just that. 

The digging for memories of abuse, and the credulous acceptance of memories that 
seem to defy all reason, has led to a broader acceptance of the harmful conspiracy 
theories now espoused by organizations like S.M.A.R.T. among some clients and 
therapists in Recovered Memory Therapy. 

Secret military mind-control projects and highly organized international rings of 
Satanic Ritual Abuse form an ever-widening circle of perpetrators that now often 
envelopes local police forces, the FBI, CIA, and government officials (as well as the 
nearly anonymous, middle-class parents of the MPD client) as believers in the pristine 
untainted nature of recovered memories attempt to explain away contradictory evidence 
that serve to disprove their fabrications of abuse. All such debunking evidence is seen 
as dis-information and cover-up. 

Arguably, Ross did much to build the mythology of Satanic Ritual Abuse that formed 
the core of what sociologists now refer to as the "Satanic Panic", a modern witch-hunt 
that arose in the eighties, continuing into the mid-nineties, and leading to many false 
convictions and fruitless investigations of unlikely crimes. 

A former patient in the care of Dr. Ross, Roma Hart, described to the author how she 
came to be implanted with false memories of Satanic Abuse under Ross's direct 
influence. Her story sheds much light on Ross's more broad appeal to the paranoid and 
delusional. The following are excerpts from an interview with Roma Hart, the full 
transcript of which can be read here: www. Process.org 

[...] How often did you see [Dr. Colin Ross], and what was the "therapy" at that 
point? 

I saw him twice a week for an hour to two hours. It was hypnotherapy. He made some 
tapes for me to listen to all day. He had me do 'dream-imaging', where at the end of 
each session he'd ask me to think about whether certain things had happened to me. 
My homework was to go home and dream about these things. I'd come back the next 
session and say, / dreamed about those things, and this was what I was dreaming. And 

5. A number of case studies regarding therapeutically created false memories may be 
found on the False Memory Syndrome Foundation website - a priceless resource for 
anybody interested in the topic, http://www.fmsfonline.org/retractl.html 



he would always say, Those dreams you had are actually flash-backs of real events in 
your life. So it proceeded very quickly into insanity. So about two months after I 
started seeing him, I was committed into the hospital's Psych Ward. 

And all the while he was telling you to recall your dreams as memories? 

He would give me something to think about. I had homework to do. He would plant the 
thought in my head that this is what I was supposed to try to see if I could remember. 
Of course I would dream about it, because what else are you going to do when you're 
deep in therapy? When somebody tells you to think about this, you'll go home and you'll 
dream about it, you come back and you say, / had this terrible nightmare about what 
you said. 

Ah, well, that's a flash-back. It really did happen. 

And I would say to him, J don't remember that happening. The first time I saw him - the 
first visit, I told him - he asked, were you ever abused as a child? I was raised in the 
sixties by military parents, because my father was an aerial cartographer. They were 
very strict. I said, what do you mean by abuse? I mean, they were strict, but they 
never abused me. I made it very clear to him that my parents never, at any time, ever 
sexually abused me, or anybody. But he said it was normal to deny it. 

So eventually you were made to come to agree that you had been sexually 
abused? 

I was told by Colin Ross that I fit the description of somebody who was sexually 
abused... Even though I swore it never happened. He said, you fit the description. All 
people with MPD have been sexually abused [according to Colin Ross]. 

I know about Colin Ross. He has written [several conspiracy theory books ]. 
How specific was his story for you? Did he develop a specific narrative for you 
that fit his conspiracy theory [and explained your supposed MPD]? 

Oh, absolutely. As I said, my father was in the military. This was when I was a tiny 
little girl, he was in the Air Force. And for Colin Ross, for anybody who's ever been in 
the military, he just makes the immediate leap into CIA, for crying out loud. He asked 
me if the words - what was it? - 'beta'... 'gamma'... and, um... 'omega', I think it was 
[meant anything to me]. Those three. He said that children were put in to CIA 
experiments where they used goggles on [the children's] eyes and hypnotized [them]. 
[The CIA programmed personalities] were either one of those: beta, omega, alpha, one 
of those. One [of these designations programmed the child so that they] would commit 
suicide, one would be given the job to dispense disinformation, the other was [...] an 
assassin. I just thought 'gamma' sounds too stupid, 'alpha' sounds like alphabet soup, 
for crying out loud, I think I chose Omega, or something like that. I chose the one that 
sounded the least stupid to me, because I was just trying to cooperate with him. There 
was just no way you could argue with him. He'd always just twist things around. You 
couldn't possibly argue with him. He'd always just say that you fit the description, 
absolutely fit the description. It has to be this. 

So in his mind, you had to be Omega, or Gamma, etc. You couldn't be None of 
The Above? 

No. Not at all. No. He was very much involved in [the idea of] CIA mind-control 
nonsense . And then he would give you jobs to do, homework to do at home. You were 
supposed to close your eyes and you were supposed to visualize different parts of the 
city so that you could leave your body and travel around the city. Then you'd come back 
for your next appointment and he'd say, So did you go anywhere? Did you see anything 
for these out-of-body experiments he was putting you into? I would say, / don't think I 
did. I don't know. I tried the best I could. You'd just try to please him so much 
because he just had this charisma, and you'd want to please this guy. He was very 



affectionate with all of his patients. He would give hugs, he'd rub your back and rub 
your legs. In those days he was just so charismatic. He was such a good-looking young 
psychiatrist. All the nurses would just pander to him like puppies... So here we were: 
young women as MPD patients trying to please this handsome, young, charismatic guy 
who was giving [us] all of his affection. 

Did Colin Ross encourage you to take action against your parents under the 
assumption that they sexually abused you? 

Yes. When I was at my most insane, under the most drugs, he encouraged me to get a 
rifle and go up and shoot them. He also encouraged me to kill myself constantly, saying 
it would be quite understandable. He would phone me late at night - and he did that to 
other patients too, because there was an MPD support group, and we'd all talk to each 
other and visit each other - he'd send us home with lethal amounts of drugs, phone us 
up at night, and encourage us to kill ourselves. One of the reasons I figure he did that 
was because he had this interest in the 'white-light' Near Death Experience. So after 
we'd come out of comas, or what-not, from drug over-doses, the first thing he'd ask us 
was, Well, did you see the light? That's all he was interested in. Some of the other 
women died though. But he really didn't care about that. He just said it was fate. 

And what exactly did he say his research was? 

Multiple Personality Disorder and [that research into alleged] mind control experiments 
with the CIA - and Satanic Ritual Abuse, for crying out loud! He explained this to me the 
first month I started seeing him. There was a sign above the planetarium, and I saw it 
on my way to see him. It was the silliest thing. It was going toward Christmas and they 
were talking about the star of [Bethlehem], and that made [Colin Ross] start 
commenting about aliens. The star [of Bethlehem, according to Colin Ross] wasn't really 
the star of Jesus - it was an alien ship that they were really seeing. So then he 
explained that lots of people had been abducted by aliens, and that women had been 
abducted by aliens and impregnated by aliens, and they have these alien babies. Now, I 
think I already said to you that at that time when I started seeing him I was a 
Pentecostal Christian Fundamentalist. I belonged to Church, was a Sunday School 
teacher. All I could think was, How horrible! How could Cod let that happen? And what 
about the baby? Would it have a soul? So, in my mind, I was horrified. Completely 
horrified. I wouldn't even talk about it. I couldn't even talk about it. I just didn't want 
to talk with anyone. But then, a few years later - I think it was 1990, somewhere 
around then - he came up from a conference in Chicago. He'd seen [infamous MPD 
therapist] Bennett Braun and the International Association of Dissociation and MPD, and 
that. He came in the hospital to see me and he said, Oh, I have great news for you! He 
was so excited, so happy and bubbly. I looked at him and thought, Good. Great news. 
What is it? And he said, You know that baby that you had? The half alien baby? It 
didn't die! Thinking that it had died was [according to Colin Ross] the only way that I 
could resolve it in my mind, so that I wouldn't have to worry about the soul. So he 
thought for me, telling me that it didn't die was going to be some good news. I looked 
at him absolutely horrified. I said, What are you talking about? At the conference he'd 
just been to, it had explained why all of the Satanic Ritual Abuse cases that they'd 
always talk about, where women give birth to these babies and they kill the babies - but 
nobody can ever find the bodies of these babies - [the conference Colin Ross attended 
explained that] the reason they can't find the bodies of these babies is because the 
bodies of these babies are beamed up into spaceships, and they're raised in the 
spaceships until they're 18 years old. Then they're beamed back down to earth and 
given jobs with the CIA. This is all to form a New World, and all that. So it's really the 
aliens who are impregnating the women, while they're CIA mind-controlled, and then 
they give birth at Satanic rituals. It's a big circular thing. It's the craziest circular thing 
I ever heard in my life. But I was horrified. I burst into tears. I couldn't believe he just 
told me that my alien baby was alive. But he was so confused. He didn't know why I 
wasn't happy. 



So - your malpractice proceedings : You didn't end up even getting a settlement, 
did you? 

No. Because I am on welfare disability, the only money I could raise for lawyers was 
just through begging people that I was given contact numbers for. [I would be told] 
This lawyer hates [Colin Ross], this doctor hates him. And this other man - his daughter 
died under Colin Ross's care, and he helped me with some money too. So I did manage 
to drag it through the system for 11 years with 4 different lawyers. But, because my 
second to last lawyer did such an atrociously bad job - and he admitted to his negligence 
to the Law Society - it was dismissed due to delay. And then Colin Ross's lawyer 
managed to have the costs awarded against me. So I owed Colin Ross something like 
100 to 200 thousand dollars - something astronomical. So I had to appeal that. So I 
had to raise another 5 thousand dollars to appeal that, and then the Law Society threw 
in another 20 to 30 thousand dollars to pay the lawyer to help me appeal that, so I 
would have the costs removed. And that was Judge Sinclair's order that I sent down to 
you. It says that, reason for dismissal due to delay, fault of my counsel. And the costs 
were taken off. I didn't have to pay the costs. 

As crazy as Roma Hart's story may appear on the face of it, a prior knowledge of MPD 
therapy and Ross's conspiracism at the very least render her narrative plausible. 
Corroborating court documents and sworn affidavits, as well as an eerily similar charge 
of malpractise brought to trial by a Ms. Tyo in Texas (where Ross relocated after leaving 
- perhaps involuntarily - the Manitoba hospital where Hart was treated), make Ms. Hart's 
claims very difficult to dismiss. 

Nonetheless, not long after posting my interview with Ms. Hart online, Ross objected 
publicly to the piece. Directing his comments to me he asked that I "investigate these 
allegations against [Ross] with the same skepticism and rules of evidence that [I] would 
bring to bear on a claim of the supernatural or the paranormal, or a conspiracy theory. 
The allegation is that the Government of Manitoba, the University of Manitoba, the 
College of Physicians and Surgeons of Manitoba and St. Boniface Hospital conspired to 
cover up malpractice by [Ross] and [his] being fired." 

Ross further objected that he had not yet written about Satanic Ritual Abuse at the time 
of his treatment of Ms. Hart, thus, supposedly, indicating that he could have suggested 
no such scenario during her therapy. He cited the fact that he still holds medical license 
as evidence that he was unlikely to have committed such egregious malpractice. 
I replied: "Certainly I am sensitive to the idea of promoting false or unfounded 
allegations. For this reason I am very thorough in matters such as this. If the allegation 
is, as you say, 'that the Government of Manitoba, the University of Manitoba, the College 
of Physicians and Surgeons of Manitoba and St. Boniface Hospital conspired to cover up 
malpractice by me and my being fired,' then the counter-allegation must be that several 
individuals independently and (in the cases of Hart and Tyo) geographically unrelated, 
confabulated a very bizarre, unlikely, and specific narrative regarding your therapeutic 
practice. Further, Ms. Tyo won a rather large settlement. While Ms. Hart's case ran over 
the Statute of Limitations, the Law Society of Manitoba found her case 'winnable' thus 
agreeing to pay her legal charges in compensation of Allan Baker's incompetence. These 
facts remain unchanged though you still hold medical license." 

Hoping to prod Ross toward specifying his position on Satanic Ritual Abuse and other 
conspiracies, I continued: "I make no mystery that I feel the events we now refer to as 
the Satanic Panic were the workings of delusional paranoiacs and heart-less 
opportunists. To me, it matters little that your first publication regarding Satanic Ritual 
Abuse comes before or after a certain point. The fact is, your work on SRA comes highly 
recommended by those who still wish to keep the righteous witch-hunts of the eighties 
(to mid-nineties) alive. For this reason I would ask you not to be elusive: Do you find 
merit in the claim that there is an organized, underground society or agency 
systematically engaging in Ritual Abuse for the purpose of mind-control? Such a belief, 
in my view, is delusional. For a man in your position (most-cited among panic-mongers), 
I feel that not explicitly distancing yourself from those beliefs, if you don't in fact hold 



them, is grossly irresponsible. As you know, claims of Satanic Ritual Abuse are nearly 
universally disregarded as an artifact of a hysteria by nearly all professions but for those 
in a certain sub-set of the psychotherapeutic world. Within this world, your work is felt to 
be vital in understanding the vile machinations of a global satanic mind-control plot. If 
you came to disregard claims of Satanic cult activity in the course of your work, you'd 
possibly do much good for those still afflicted with such delusions to explain how you 
reached your conclusions." (The exchange can be read here ) 

Unfortunately, Ross refused to state what it is he actually believes, citing "various", but 
unspecified reasons for reserving comment: "Your argument that geographically 
separated people could not have come up with the same story unless it was accurate is 
the same argument that therapists used in the late 80s/early 90s to 'validate' SRA. I 
have never given an estimate of the % of SRA memories that are accurate and decline 
to do so now for various reasons." 

And in that mystifying statement, Ross both seemed to scoffingly dismiss the question of 
Satanic Ritual Abuse (by referencing the flawed arguments that were used to validate 
SRA), and confess a belief in it at the same time (by presupposing the existence of 
accurate SRA memories in his decision to refrain from stating an estimate of legitimate 
cases... though it's worth mentioning that I'd never asked him to do so.) 
It is true though, that during the height of the Satanic Panic, therapists invested in 
conspiracist notions of Multiple Personality Disorder origins were quite fond of citing the 
consistency of Satanic Abuse tales arising from various clients across a broad range of 
communities as evidence of the phenomena's basis in actual events. The difference 
being, of course, that we know how these geographically unrelated subjects came upon 
their "memories" of SRA. They were treated by therapists who felt they knew how to 
recognize the symptoms of SRA - therapists who drew out exactly the memories they 
were looking for. Therapists, I daresay, who derived much inspiration from the works of 
Dr. Colin Ross. 

But that was that. No more clarifying comments from the esteemed dissociative 
disorders doctor. Being that I have witnessed first-hand at the S.M.A.R.T. conference 
that the myth of amok Satanic cults is still ruining lives, I couldn't but see Dr. Ross's 
avoidance of the Satanic Ritual Abuse question as a profound failure of character, or 
critical thinking. 
Perhaps both.